[The appeal against this decision is reported at [2006] BTC 131.]

Dr J F A Jones CBE

Decision released 22 February 2005

Capital Gains Tax – shareholder giving shares in private company to a company held within an insurance bond – whether the former shareholder and the insurance company were connected persons as acting together to secure or exercise control of the donee company with the result thats. 167 TCGA 1992 prevents hold-over relief on the gift of shares from applying – yes – appeal dismissed

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