Inland Revenue Commissioners v Garvin and Rose [1981] UKHL TC_55_24 (14 May 1981)

Inland Revenue Commissioners v Garvin and Rose [1981] UKHL TC_55_24 (14 May 1981)

Income tax and surtax – Transactions in securities – Tax advantage – Counteraction – Sale of shares in property companies – Subsequent payments of abnormal dividends by property companies – Whether relevant circumstances present – Whether sale of shares transactions “whereby” another person received abnormal dividends – Whether purchase price of shares received “in connection with” re-acquisition by vendors of shares of assets of property companies – Whether property companies were at material time companies to which para of s 461 applies – Insufficient evidence in Case Stated – Whether onus on taxpayer or Crown – Whether tax advantages obtained – Income and Corporation Taxes Act 1970, s 460, paras C and D of s 461, proviso to para D(2) ofs 461, s 466 and s 467(2).
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