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HMRC internal manual

Capital Gains Manual

Group share exchanges: NAP Holdings UK Ltd v Whittles

The Woolcombers case concerned losses and became final in the Court of Appeal. The view adopted by the Revenue in response to the Woolcombers decision was subsequently challenged in a case involving gains, NAP Holdings UK Ltd v Whittles (67TC166). In a judgement given on 17 November 1994 the House of Lords upheld the application of the Woolcombers decision to group share exchanges before 15 March 1988.