Chancery Division.

Park J.

Judgment delivered 31 July 2001.

Capital gains tax – Computation – Chargeable gains – Acquisition of asset – Reorganisation of share capital – Arrangement between existing company and two classes of shareholder under which two new companies issued shares to shareholders of existing company – Whether arrangements between original company and shareholders of original company entered into for purposes of reorganisation or amalgamation – Capital Gains Tax Act 1979, s. 86 (now Taxation of Chargeable Gains Act 1992, s. 136).

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