Jerome v Kelly (Inspector of Taxes)

Citation:

[2004] 1 WLR 1409, House of Lords [2004] UKHL 25

Judgment Date:

13 May 2004

Robert Venables QC and Amanda Hardy for the taxpayer.

Revenue — Capital gains tax — Disposal of assets — Bare trustees of land entering into contract to sell land — Before completion of contract beneficial owners assigning part of beneficial interest to non-resident trustee of overseas settlement — Bare trustees completing sale — Whether beneficial owners liable to capital gains tax on proceeds of sale belonging to overseas trustee — Whether date of contract date of disposal — Whether beneficial owners parties to disposal — Capital Gains Tax Act 1979 (c 14), s. 27(1)