United Kingdom House of Lords Decisions

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Cite as: [1988] UKHL TC_62_1

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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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