Case Law

Patrick W Keane & Co v The Revenue Commissioners 2008 ITR 57 considered whether a transaction constituted a reconstruction or partition for the purpose of this section.

Baytrust Holdings Ltd v IRC 1971 3 All ER 76 considered the meaning of ‘reconstruction’ and ‘undertaking’.

In Crane Fruehauf Ltd v IRC 1975 STC 51 an amalgamation was the coming together of two companies so that they were, after the transfer, owned by the same persons as before.

In E. Gomme Ltd v IRC 1964 3 All ER 497 the term undertaking was held to relate to the gross value of the undertaking.