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.’
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England and Wales
Cited – Revenue 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.
Updated: 15 April 2022; Ref: scu.428301