[2004] UKPC 16.

Privy Council.

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).

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