TATEM STEAM NAVIGATION COMPANY, LTD. v. COMMISSIONERS OF INLAND REVENUE.

(1941) 69 Ll L Rep 132

KING'S BENCH DIVISION.

Before Mr. Justice Lawrence.

Revenue-Super tax-"Company in which the public are substantially interested" -Shipping company under control of not more than five persons-Gift of shares by principal shareholder to niece as an accretion to her marriage settlement funds-Principal shareholder a trustee of the marriage settlement- Provisions of Sect. 21 of Finance Act, 1922, applicable to company under the control of not more than five persons and which is not a company in which the public are substantially interested - "A company shall be deemed to be a company in which the public are substantially interested if shares of the company . . . carrying not less than 25 per cent. of the voting power have been allotted unconditionally to, or acquired unconditionally by, and are at the end of the year or other period for which the accounts of the company have been made up as aforesaid beneficially held by, the public . . . and any such shares have in the course of such year or other period been the subject of dealings on a stock exchange in the United Kingdom and the shares have been quoted in the official list of such a stock exchange"-Evidence of quotation of shares on stock exchange-Whether niece a member of public-Meaning of "public"- Unconditional allotment - Finance Act, 1922, Sect. 21 (6), as amended by Finance Act, 1927, Sect. 31 (3).