He filled in the share transfer forms on 30 March 1943, and handed them to the Mrs Rosamond Rose, who gave them to the company.

But the company registered the claimants as shareholders in Mr Rose’s place on 30 June 1943.

The Court of Appeal held that the transfer took place in March, meaning the taxes were not due.

Once he did this he was not at liberty to merely cancel the transfer, and so when he handed away the forms, the shares were held on constructive trust.

Here the donor (Mr Rose) had done everything in his power that he had needed to do to make the transfer effective.