Court of Appeal
*Good
v
Revenue and Customs Commissioners
[2023] EWCA Civ 114
2022 Oct 19, 20; 2023 Feb 10
King, Snowden, Whipple LJJ
RevenueIncome taxEntitlement to incomeTaxpayer entering into tax avoidance scheme involving purchase of film rights partially funded by loan followed by sale of film rightsTaxpayer receiving minimum annual payments as consideration for sale but assigning right to receive them to lenderWhether taxpayer liable to income tax on minimum annual paymentsWhether taxpayer “entitled to” such payments notwithstanding assignmentWhether 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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