Unilever (UK) Holdings Ltd v Smith (Inspector of Taxes)

Citation:

[2002] All ER (D) 147 (Dec) and [2002] EWCA Civ 1787

Judgment Date:

11 December 2002

Robert Venables QC and James Kessler (instructed by James Berkeley, Unilever (UK) Holdings Ltd Legal Department) for the company.

Capital gains taxation – Exemptions and reliefs – Allowable losses – Loss resulting from disposal of company allowable if shares in that company held as a result of a ‘new holding’ resulting from a ‘reorganisation’ within meaning of statute – Meaning of ‘new holding’ and ‘reorganisation’ – Taxation of Chargeable Gains Act 1992, s 126.