Special Commissioners' Decisions

Italian complications

The appellant received a substantial inheritance when his aunt died in March 1992. He completed the inventory in relation to his aunt's estate in August 1993 and included thereon was a sum which had been paid to the Italian authorities claimed as an allowance against tax. However part of that sum related to tax due from the aunt's estate following the death of her husband. Thus that amount should have been declared as a debt on the estate rather than as foreign tax on the aunt's estate. Eventually an amount of tax approximately £12 500 was agreed between the Revenue and the appellant. However this was not paid.

Before the Special Commissioner the appellant said that a sum of some £10 000 was still awaiting settlement by or payment to the Italian revenue authorities. He was in the process of...