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18 October 2007
Categories:
Tax cases
Retirement Care Group Ltd (as trustees) (SpC 607)
A company was the trustee of service trust funds which it held in trusts under the Landlord and Tenant Act 1987, s 42. HMRC ruled that this income was taxable at the rate applicable to trusts and the matter was referred to the Special Commissioner.
The Commissioner found that the income was income to be accumulated within TA 1988, s 686, and was therefore taxable at the rate applicable under s 686(1AA) and (1A). There was no basis for implying any other limitation of the categories of trust falling in s 686.
Retirement Care Group Ltd (as trustees) (SpC 607)
Categories:
Tax cases
