An individual who exchanged shares in a company for loan notes issued by the purchaser was denied a capital gains tax roll-over because he intended to cease to be tax resident in the UK before the loan notes were redeemed. This is the effect of the High Court's decision in Vincent Snell v Commissioners for HMRC, interpreting section 137 of the Taxation of Chargeable Gains Act 1992. The decision indicates that CGT roll-over treatment may not be available if the seller intends to convert a CGT roll-over into a permanent tax exemption. However, the case does confirm that a seller of shares can defer capital gains tax on the disposal of shares by exchanging the shares for loan notes issued by the purchaser.