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Michael Black (1) Stephen Brown (2) Gregory Green (3) Malcolm White (4) v. HMIT – SC 3106-9/99

The appellants appealed against various assessments to income tax under Schedule E. The amounts appealed against were received by the Appellants in the form of units in a unit trust provided to them by their employer. It was agreed that the amounts were taxable under Schedule E as emoluments from employment. The issue was whether the employer ought to have deducted income tax under s.203 ICTA 1988 and the 1973 Regulations before providing the units to the Appellants. The Commissioner held that the employer ought to have deducted income tax before providing units to the Appellants. Importantly (though this was not argued by the Taxpayers) the Commissioner held that the transfer of units in a unit trust was a “payment” within s.203 ICTA 1988.

Hugh McKay (instructed by The Taylors Partnership, Chartered Accountants) for the Appellants

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