p926 CPAG refers to R v Caerphilly CBC HBRB ex parte Jones, 1 Feb 1999, unreported as a HB case where the court decided there was no evidence of intention as the sole purpose of the arrangement was so that the relative would be gifted the discount value.

Does anyone have a copy of this case i could request or a link to where i might find it?

here you go ....

http://www.bailii.org/ew/cases/EWHC/Admin/1999/83.html

That's great

thanks