Case Law

National Westminster Bank plc v IRC 1994 3 All ER 1 considered the meaning of the issue of shares.

The percentage shareholding refers to the nominal value and not the real value of the shares. Canada Safeway Ltd v IRC 1972 1 All ER 666

In Central and District Properties Ltd v IRC 1996 2 All ER 433 options given over shares were deemed to form part of the consideration and consequently relief was not available as less than 90% of the consideration was in the form of shares.

In Brooklands Selangor Holdings Ltd v IRC 1970 1 All ER 76 a company could not deal as it pleased with its shares in another company, but was bound to transfer them to another. It was held that the company was not the beneficial owner of those shares.