The Weekly Law Reports
[1960] 3 WLR 414
[CHANCERY DIVISION.]
INLAND REVENUE COMMISSIONERS v. HARTON COAL CO. LTD.
1960 May 31;
June 1, 3.
June 1, 3.
Pennycuick J.
Revenue
— Surtax
— Company
— Subsidiary company
— Direction that company's income be treated as members' income
— Shares held by three companies
— “Management” share held jointly in beneficial ownership by two companies
— Whether “control”
— Whether a “subsidiary company”
—
Finance Act, 1922 (12 & 13 Geo. 5, c. 17), s. 21 (6)
—
Finance Act, 1936 (26 Geo. 5 & 1 Edw. 8, c. 34), s. 19 (1) (a)
—
Finance Act, 1937 (1 Edw. 8 & 1 Geo. 6, c. 54), s. 14 (1)
—
Income Tax Act, 1952 (15 & 16 Geo. 6 & 1 Eliz. 2, c. 10), ss. 245, 256.
Company
— Control
— Company surtax purposes
— Whether control related to beneficial ownership
—
Finance Act, 1922, s. 21 (6)
—
Finance Act, 1936, s. 19 (1) (a)
—
Finance Act, 1937, s. 14 (1)
—
Income Tax Act, 1952, ss. 245, 256.