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News - tax cases

14 August 2006
Categories: Tax cases
Bank of Ireland Britain Holdings Ltd (SpC 544); Scrace and another v CRC; Scottish Exhibition Centre Ltd v CRC; Legal & General Assurance Society Ltd v CRC; R (on the application of Silicon Graphics Finance SA) v CRC; Borchert (SpC 545); Rowland (SpC 548); London Recruitment Services Ltd (SpC 546)

Bad fit

On 8 November 2000 the ordinary share capital of P a Cayman Islands resident company was issued to B another Cayman Islands company. The next day 225 000 £1 shares in P were issued to B for £1 000 a share. On 10 November agreements comprising the repo transaction were entered into. First B entered into a share sale agreement with the bank whereby B would sell the securities to the bank for £225 million on 14 November. The bank promised not to transfer the securities to anyone other than the appellant a private limited UK resident company. Second under the first option agreement between the bank and the appellant the bank granted the appellant a call option on the securities and the appellant granted the bank a put option on the securities so that either party could...

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