The Weekly Law Reports
[1997] 1 WLR 1071
[HOUSE OF LORDS]
INLAND REVENUE COMMISSIONERS APPELLANTS AND WILLOUGHBY (PETER GEOFFREY) RESPONDENT
SAME APPELLANTS AND WILLOUGHBY (RUTH MARYLYN) RESPONDENT
[CONSOLIDATED APPEALS]
1997 March 10;
July 10
July 10
Lord Nolan, Lord Mustill, Lord Hoffmann, Lord Clyde and Lord Hutton
Revenue
— Tax avoidance
— Transfer of assets abroad
— Investment in offshore personal portfolio bond
— Bond allowing investor continued control over investment policy
— Whether anti-avoidance provision applicable to bond purchased by non-resident investor
— Exemption provision where tax avoidance not purpose of transfer of assets
— Whether facility for investment control making bond vehicle for tax avoidance
—
Income and Corporation Taxes Act 1988 (c. 1), ss. 739(1)(2), 741(a)
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