Surtax – Undistributed income of trading company – Control transferred during accounting period to company outside Section 245, Income Tax Act, 1952 – Whether income can be apportioned to members prior to transfer – Resolution to pay no dividend on ordinary shares followed by resolution at later date to pay a dividend – Whether dividend paid within reasonable time – Income Tax Act, 1952 (15 and 16 Geo. V I and l Eliz. II, c.10), Sections 245, 248(1) and 256(2)(c)(i) and (4)
Citations:
[1963] UKHL TC – 41 – 92
Links:
Statutes:
Jurisdiction:
England and Wales
Income Tax
Updated: 17 June 2022; Ref: scu.559258
