The Law Reports (Appeal Cases)
[1958] AC 549
[HOUSE OF LORDS.]
ESCOIGNE PROPERTIES LTD. APPELLANTS; AND INLAND REVENUE COMMISSIONERS RESPONDENTS.
1957 Nov. 20,
21.
1958 Jan. 23.
1958 Jan. 23.
VISCOUNT SIMONDS, LORD REID, LORD KEITH OF AVONHOLM, LORD SOMERVELL OF HARROW and LORD DENNING.
Revenue
— Stamp duty
— Conveyance or transfer on sale
— Company having contracted for purchase of property agrees to re-sell to second company
— Conveyance to second company by executors of original vendor when first company beneficial owner of not less than 90 per cent. of other company's share capital
— Whether “the effect” of conveyance to transfer a beneficial interest from one company to another
— Whether conveyance executed in pursuance or in connexion with arrangement whereunder beneficial interest had been previously conveyed or transferred
—
Stamp Act, 1891 (54 & 55 Vict. c. 39), ss. 54, 58 (4), Sch. I
—
Finance Act, 1930 (20 & 21 Geo. 5, c. 28), s. 42
—
Finance Act, 1938 (1 & 2 Geo. 6, c. 46), s. 50.
Statute
— Construction
— Object of Act
— Relevance of specific instances intended to be covered by it.