Craven v White [1988] UKHL TC_62_1 (21 July 1988)
Capital gains tax – Disposal – Tax avoidance Scheme – Composite transaction – Preordained series of transactions – Shares in United Kingdom company exchanged for shares in isle of Man company followed later by sale to purchaser company – Second transaction not certain when first transaction carried out – Whether series of transactions to be treated as single composite transaction – Finance Act 1965, s 19(1), Sch 7 paras 4 and 6. Development land tax – Tax avoidance scheme – Composite transaction – Fragmentation of land prior to sale for multiple exemptions – Purchaser ending negotiations before sale agreed – Sale completed later on terms different from those originally proposed – Whether series of transactions to be treated as single composite transaction – Development Land Tax Act 1976, ss 1, 12. Assessment – Mistake – Vacation – Year wrongly stated on assessment – Taxpayer not misled – Assessment unilaterally vacated by H.M. Inspector – Whether mistake on assessment could be disregarded – Whether unilateral vacating of assessment by Inspector possible – Taxes Management Act 1970, ss 29(6), 114.
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