Reviewed case brief

Commissioner of Inland Revenue v Crossman

[1937] AC 26

The House of Lords held that shares are not merely a right to a proportionate share in assets but represent a "bundle of rights" defined by the company's Articles. Restrictions on transfer in the AOA must be factored into valuation. The decision clarified that shares derive their character from the

sharesvaluationbundle-of-rightsAOA-restrictions
Court
House of Lords
Year
1937
Subjects
Company Law
Reviewed
2026-06-30

Rule established

The value of shares for estate duty purposes includes all rights attached to them under the Articles of Association, including restrictions on transfer; shares represent a bundle of rights.

Facts

    Issues

      Held

        Ratio decidendi

        How to use it in an exam

        Editorial source

        [1937] AC 26

        Educational summary only. Read the reported judgment or an authorised law report before relying on the case professionally.