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INTERNATIONAL U.K. House of Lords

Vestey v Inland Revenue Commissioners (No1) [1979] UKHL TC_54_503 (22 November 1979)

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Vestey v Inland Revenue Commissioners (No1) [1979] UKHL TC_54_503 (22 November 1979)

Income tax – Avoidance of tax – Transfer of assets – Income payable to trustees of settlement resident abroad – Income accumulated and invested – Income from such investments also accumulated and invested in two funds – Investments including shares in wholly-owned overseas companies – Capital sums paid out of each fund to discretionary beneficiaries (other than the transferors) ordinarily resident in the U.K. – Capital sum paid to mother of infant beneficiary – Whether infant “received” or “entitled to receive” such capital sum – Whether each of such beneficiaries had “power to enjoy” income of (a) the trustees, (b) the overseas companies – Whether such income deemed to be income of each of such beneficiaries in years prior to, including, and subsequent to, year of receipt – Power of Board of Inland Revenue to apportion such income between selected beneficiaries – Income Tax Act 1952, s 412 (1), (2), (4), (5) & (6) – Finance Act 1969, s 33 – Inland Revenue Regulation Act 1890, s 1 – Taxes Management Act 1970, s 1.
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Source: https://www.bailii.org/

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