HL Income tax and surtax – Transactions in securities – Tax advantage – Counteraction – Sale of shares in property companies – Subsequent payments of abnormal dividends by property companies – Whether relevant circumstances present – Whether sale of shares transactions ‘whereby’ another person received abnormal dividends – Whether purchase price of shares received ‘in connection with’ re-acquisition by vendors of shares of assets of property companies – Whether property companies were at material time companies to which para of s 461 applies – Insufficient evidence in Case Stated – Whether onus on taxpayer or Crown – Whether tax advantages obtained – Income and Corporation Taxes Act 1970, s 460, paras C and D of s 461, proviso to para D(2) ofs 461, s 466 and s 467(2).
Citations:
[1981] UKHL TC – 55 – 24, [1981] TR 215, [1981] WLR 793, 55 TC 24, [1981] STC 344
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 27 June 2022; Ref: scu.559844
