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Dunlop International Ag v Pardoe (Inspector of Taxes): CA 5 Oct 1999

Where a company ceased to be resident in the UK, and there was deemed as a result to be a transfer of shares between companies within the group, that transfer gave rise to a chargeable gain which was chargeable to Corporation Tax. Citations: Times 05-Oct-1999 Statutes: Income and Corporation Taxes Act 1970, Taxation of Chargeable … Continue reading Dunlop International Ag v Pardoe (Inspector of Taxes): CA 5 Oct 1999

Johnston Publishing (North) Ltd v HM Revenue and Customs: ChD 14 Mar 2007

The court was asked as to the applicability or not of deeming provisions in relation to the taxation of chargeable gains arising out of what may or may not be group transactions, and in particular the meaning and effect, in context, of the word ‘associated’ where it appears for the second time in section 179(2). … Continue reading Johnston Publishing (North) Ltd v HM Revenue and Customs: ChD 14 Mar 2007

Unilever (UK) Holdings Ltd v Smith (Inspector of Taxes): CA 11 Dec 2002

The company entered into an approved scheme of arrangement under which the entire preference shares were cancelled. The company appealed a refusal to recognise the arrangement as a re-organization of the company with a deemed disposal and re-acquisition of the holdings of the shares at market value. Held: It was of the essence of a … Continue reading Unilever (UK) Holdings Ltd v Smith (Inspector of Taxes): CA 11 Dec 2002