STANTON (INSPECTOR OF TAXES) APPELLANT AND DRAYTON COMMERCIAL INVESTMENT CO. LTD. RESPONDENTS

Citation:

[1982] 3 WLR 214

Judgment Date:

08 July 1982

 (Corporation tax on chargeable gains – issue of own shares by company in exchange for portfolio of investments – acquisition cost)

Revenue — Corporation tax — Chargeable gains — Allowable deductions — Investment company acquiring securities in exchange for issue of its own shares — Conditional agreement stipulating price of securities and number of shares to be issued in exchange — Market value of shares falling before completion of agreement — Value of consideration given for securities — Finance Act 1965 (c. 25), Sch. 6, para. 4 (1) (a)