The Weekly Law Reports
[2023] 1 WLR 2062
Court of Appeal
*Good
v
Revenue and Customs Commissioners
[2023] EWCA Civ 114
2022 Oct 19, 20; 2023 Feb 10
King, Snowden, Whipple LJJ
Revenue— Income tax— Entitlement to income— Taxpayer entering into tax avoidance scheme involving purchase of film rights partially funded by loan followed by sale of film rights— Taxpayer receiving minimum annual payments as consideration for sale but assigning right to receive them to lender— Whether taxpayer liable to income tax on minimum annual payments— Whether taxpayer “entitled to” such payments notwithstanding assignment— Whether assignment absolute so as to pass legal title to lender—
Law of Property Act 1925 (15 & 16 Geo 5, c 20), s 136[1]
—
Income Tax (Trading and Other Income) Act 2005 (c 5), ss 609, 611[1]
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