Appeal from the Decision of Lightman J of 14 October 1998 (Click here)Sub-underwriting activities of the Post Office and British Telecom Pension schemes did not constitute trading within Case I of Schedule D. Instead, the sub-underwriting itself formed an integral part of the schemes’ investment process and took its colour therefrom. Accordingly the sub-underwriting commission was income chargeable under Case VI of Schedule D, but exempted by s.592(3) ICTA 1988.In the context of s.686(2)(c) ICTA 1988, the word ‚Äö√Ñ√∫property‚Äö√Ñ√π was not wide enough to encompass a trade. Therefore, s.686(2)(c) did not exempt pension fund trading income from the additional trade of tax applicable to trusts.Michael Flesch KC and Felicity Cullen appeared for the pension fund trustees
Trustees of British Telecom Pension Scheme & others v. Clark (HMIT) (Court of Appeal)
GITC is sad to report the death of our Head of Chambers, Mr Milton Grundy who passed away at the weekend.
Gray’s Inn Tax Chambers is deeply saddened by the passing of our founding member and Head of Chambers, Mr Milton Grundy
28 Nov 2022
Gray’s Inn Tax Chambers is deeply saddened to learn of the death of Her Majesty Queen Elizabeth II.
We join the nation in mourning and our condolences are with the Royal Family.
09 Sep 2022
The 2022 GITC Review is now available
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