Mark Dunsby v The Commissioners for HM Revenue and Customs [2021] UKUT 0289 (TCC)
Upper Tribunal Tax and Chancery decision of Mrs Justice Bacon and Judge Timothy Herrington on 23 November 2021
Read full decision in
INCOME TAX – settlements legislation – chapter 5 Part 5 Income Tax (Trading and Other Income) Act 2005 – meaning of “settlement” – meaning of “settlor” – whether there were multiple settlors – application of s 644 and s 645 Income Tax (Trading and Other Income) Act 2005 – whether dividend or distribution taxable under s 383 Income Tax (Trading and Other Income) Act 2005 – whether taxpayer subject to tax by reference to the income of the settlement under transfer of assets abroad regime – chapter 2 Part 13 Income Tax Act 2007