Where the essence of a transaction was only capable of being explained as being for fiscal grounds, the mere presence of trading elements would be insufficient to turn it into a trading transaction effectively so for tax purposes.
HL Income tax, Schedule D – Loss in trade – Dealer in securities – Dividend-stripping – Whether shares bought for dividend-stripping held as stock-in-trade.
[1972] AC 634, [1971] CLY 1919, [1971] UKHL TC – 47 – 580, [1971] 3 All ER 948, [1972] AC 634, 47 TC 580, [1971] TR 284, [1971] 3 WLR 670
Bailii
England and Wales
Income Tax
Updated: 10 January 2022; Ref: scu.559818