Leigh v Inland Revenue Commissioners: ChD 1928

For income tax purposes, interest is only derived, or arises, when it is actually or constructively received or credited. Rowlatt J said: ‘Before a good debt is paid there is no such thing as income tax upon it. The meaning of the section must be ‘receivability’ speaking of a debt, which has been received, and means the date on which it is paid as distinct from the date on which it was accruing.’


Rowlatt J


[1928] 1 KB 73


England and Wales

Cited by:

CitedRevenue and Customs v DCC Holdings (UK) Ltd SC 15-Dec-2010
The taxpayer had entered into a ‘repo’ loan to its bank, agreeing to purchase a block of gilt edged securities, and to resell them at a later date at a fixed figure. The profit and figures included an allowance for the interest payments to be made. . .
Lists of cited by and citing cases may be incomplete.

Income Tax

Updated: 15 April 2022; Ref: scu.428301