Under the Income Tax Act 1853, section 2, Schedule D, British trustees acting under the marriage contract of a French lady resident abroad were assessed in respect of income from foreign securities and possessions paid to her abroad. In the second case the respondents, who were domiciled in the United Kingdom, were trustees under a will, and were assessed in respect of the income of foreign investments paid to a Swedish lady also resident abroad. Held that as the beneficiary in each case was domiciled and resident abroad the income in question was not liable for income tax merely because the legal ownership of the investments was in British trustees.
Decision of the Court of Appeal (1919, 2 K.B. 108) affirmed.
Citations:
[1920] UKHL 380, 59 SLR 380
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 20 December 2022; Ref: scu.631532
