The taxpayers were trustees of a trust which had received bonuses by way of shares issued in lieu. They appealed a finding of being taxable on the payments as income and subject to higher rates of tax.
Held: The section was poorly worded, but the argument presented by the trustess would present anomolous results. The issue of the shares vy way of an enhanced scrip dividend was to be deemed to be income within the trust.
Judges:
Lord Justice Latham The President Lord Justice Neuberger
Citations:
[2004] EWCA Civ 885, Times 17-Aug-2004
Links:
Statutes:
Income and Corporation Taxes Act 1988 249 686
Jurisdiction:
England and Wales
Income Tax
Updated: 11 June 2022; Ref: scu.198713