||All England Reporter
|| All ER (D) 48 (Apr)
|| EWHC 547 (Ch)
||David Goldberg QC and Aparna Nathan (instructed by Landwell (Solicitors) Ltd) for the appellants.
||Timothy Brennan QC (instructed by the Solicitor of Inland Revenue) for the respondent.
||8 April 2005
Capital gains taxation - Avoidance - Scheme - Residence of company for purposes of United Kingdom tax law - , s 249.
On an appeal concerning a complex scheme designed to avoid capital gains tax on part of the gain referable to a sale of trading companies the court held that the Special Commissioners had erred in law in concluding that one of the companies, the subject matter of the appeal, was resident in the United Kingdom.
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