[The appeal against this decision is reported at [2007] BTC 62.]

Dr John F Avery Jones CBE and DR Kameel Khan

Decision released 5 April 2006

Capital gains tax – exchange of shares for loan stock – TCGA 1993 s 137 – whether the exchange was effected for bona fide commercial reasons – yes –whether one of the main purposes of the scheme or arrangements including the exchange was avoidance of capital gains tax – yes – appeal dismissed

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