Robert Venables QC and Amanda Hardy (instructed by Stokes, Portsmouth) for the appellant.
Capital gains tax – Disposal of assets – Time of disposal – Contract of sale of interests in land – Assignment of part of interests to overseas settlements after contract but before completion – Contract completed in three tranches, each tranche applying to different parcel of land – Whether taxpayer assessable to capital gains tax on basis of deeming provision – Capital Gains Tax Act 1979, ss 27(1), 46(1).