The UK Court of Appeal gave its judgment on 27 January 2006 in the case of Wood v. Holden [2006] EWCA Civ 26 regarding a scheme to avoid UK capital gains tax on the sale of a controlling shareholding in a UK resident company. Details of the decision are summarized below.
(a) Facts and background. The scheme involved the taxpayers transferring their shares in the UK company to a company incorporated in the British Virgin Islands (BVI) by the trustees of various trusts established …