Fry (Inspector of Taxes) v Salisbury House Estate Ltd: HL 4 Apr 1930

A property company asserted that it should be taxed under Schedule A in respect of the rents it received from the offices it let. The Revenue sought to charge those rents under schedule D as receipts of its trade.
Held: Income tax is only one tax, and the different Schedules do no more than to provide the method of computation charge and assessment peculiar to the Schedule to which the income is allocated.
The different schedules of the Income Tax Acts are mutually exclusive so that any exemption from tax as trading income is not automatically extended to any other head of income. The same source of income cannot be taxed twice.


Viscount Dunedin, Lord Warrington of Clyffe, Lord Atkin, Lord Tomlin, Lord Macrnillan


[1930] UKHL 1, [1930] AC 432, [1930] 15 TC 266




England and Wales

Income Tax

Updated: 09 July 2022; Ref: scu.248478