The Weekly Law Reports
[1979] 3 WLR 689
[HOUSE OF LORDS]
INLAND REVENUE COMMISSIONERS APPELLANTS AND PLUMMER RESPONDENT
1979 June 19,
20,
21;
Nov. 1
Nov. 1
Lord Wilberforce, Viscount Dilhorne, Lord Diplock, Lord Fraser of Tullybelton and Lord Keith of Kinkel
Revenue
— Tax avoidance
— Sale of annuity to charity
— Surtax payer selling five-year annuity to registered charity
— Yearly sum equalling £500 after deduction of income tax paid by taxpayer in consideration for receiving £2,480 from charity
— Whether payment of “any annuity or other annual payment”
— Whether yearly payments made for “valuable and sufficient consideration”
— Whether scheme expressly designed to avoid tax falling within statutory definition of “settlement”
— Whether yearly payments deductible from total income for tax purposes
—
Income and Corporation Taxes Act 1970 (c. 10), ss. 52 (1), 434, 454 (3), 457