Inland Revenue Comrs v Bates

Additional names

Bates v Inland Revenue Comrs

Subject Matter

REVENUE — Surtax — Settlement — Trust fund — Shares in trading company — Payments by company to settlor of capital sums — Whether company a “body corporate … connected with a settlement” — Reasonable part of company's income distributed in relevant years — Whether company within statutory definition — Statutory scheme for treating as part of income of settlor capital sums paid by company to extent of “income available” — Carry-forward scheme — Whether taxpayer liable to surtax on relevant parts of capital sums — Income Tax Act, 1952, ss 245, 408, 411 (4) (a) (b)

[1968] AC 483; [1965] 1 WLR 1133; [1967] 2 WLR 60

Appellate History

Inland Revenue Comrs v Bates [1965] 1 WLR 1133; [1965] 3 All ER 64, CA

Decision of the Court of Appeal affirmed

Inland Revenue Comrs v Bates [1968] AC 483; [1967] 2 WLR 60; [1967] 1 All ER 84; 44 TC 225, HL(E)

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