In any particular case there may be considerable difficulty in deciding whether a series of transactions was ‘pre-ordained’. This is the first ingredient which, in the speech of Lord Brightman in Furniss v Dawson (see above), must exist before the new approach can apply. In the decision of the Court of Appeal in Craven v White; IR Commrs v Bowater Property Developments Ltd; Baylis v Gregory [1987] BTC 226, Slade LJ said (at p. 237):

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