Carreras Group Ltd v Stamp Commissioner.  BTC 8077
 UKPC 16.
Lord Nicholls of Birkenhead, Lord Hoffmann, Lord Rodger of Earlsferry, Lord Carswell and Lord Brown of Eaton-under-Heywood.
Judgment delivered 1 April 2004.
Transfer tax – Share transfers – Reorganisation of share capital – Debenture issued in exchange for transfer of shares – Steps taken treated as single transaction – Liability to transfer tax – Whether transaction reorganisation of capital – Whether taxpayer entitled to tax exemption – Transfer Tax Act (Jamaica).