The appellant, Mr Vincent Snell, was the beneficial owner of 91% of the issued capital in Sovereign Rubber plc ("the Company"). On 21st December 1996 he entered into an agreement ("the Sale Agreement") with Inhoco 564 Ltd for the sale of his shares for a total consideration of £7,317,000 payable as to £6,580,000 in loan stock of three separate classes, £537,000 in deferred consideration and £200,000 in payment of his costs. Mr Snell left the United Kingdom on 2nd April 1997. Initially he went to live in the Isle of Man. At the end of that year he moved to the Cayman Islands where he has lived ever since. On 8th July 1997 Mr Snell redeemed £5,630,000 of the ordinary loan stock.

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