Coll & Anor v Revenue and Customs Commissioners.  BTC 1,513
 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.