The Law Reports (Appeal Cases)
[1965] AC 1088
[HOUSE OF LORDS.]
WM. CORY & SON LTD. APPELLANT; AND INLAND REVENUE COMMISSIONERS RESPONDENT.
1965 Feb. 3,
4,
8;
March 18.
March 18.
LORD REID, LORD MORRIS OF BORTH-Y-GEST, LORD HODSON, LORD PEARCE and LORD DONOVAN.
Revenue
— Stamp duty
— Conveyance or transfer on sale
— Option to purchase share capital
— Transfers pursuant to option agreement to protect purchasers' rights
— No transfer of beneficial interest
— Subsequent exercise of option
— Whether transfers “conveyance or transfer on sale”
— “Upon the sale”
— Agreement for option to purchase
— Whether agreement for sale of equitable interest
—
Stamp Act, 1891 (54 & 55 Vict. c. 39), ss. 1, 54, 59 (1).