Escoigne Properties Ltd v Inland Revenue Comrs

Subject Matter

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 benefiial 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.

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.