[2010] UKUT 114 (TCC).

Upper Tribunal (Tax and Chancery Chamber).

John F Avery Jones (Judge) and John Walters QC (Judge).

Decision released 5 March 2010.

Capital gains tax – Disposal – Exchange of shares for loan notes – Reorganisation – Loan notes redeemed when taxpayers abroad – Whether exchange formed part of scheme or arrangements main purpose of which was avoidance of CGT liability – Intention to become non-resident – Whether position of each shareholder to be considered separately – Taxpayers' appeal dismissed – Taxation of Chargeable Gains Act 1992, s. 137.

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