[2006] EWHC 3350 (Ch).

Chancery Division.

Sir Andrew Morritt C.

Judgment delivered 21 December 2006.

Capital gains tax – Tax avoidance – Exchange of shares for loan stock – Taxpayer emigrating to Isle of Man – Loan stock subsequently redeemed – Taxpayer failing to declare gain on tax return – Revenue amending self-assessment to include tax in respect of gain – Special commissioners finding exchange effected for bona fide commercial reasons but avoidance of CGT a main purpose of scheme or arrangements including exchange – Taxation of Chargeable Gains Act 1992, s. 137.

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