Robert Venables QC and Amanda Hardy (instructed by Stokes, Portsmouth) for the taxpayer.
Capital gains tax – Disposal of assets – Time of disposal – Contract of sale of interests in land – Assignment of part of the interests to overseas settlements after contract but before completion – Whether date of disposal was the date of contact of sale – Whether property disposed of was property referred to in contract of sale – Capital Gains Tax Act 1979, ss 27(1), 46(1).