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
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INCOME TAX 鈥� settlements legislation 鈥� chapter 5 Part 5 Income Tax (Trading and Other Income) Act 2005 鈥� meaning of 鈥渟ettlement鈥� 鈥� meaning of 鈥渟ettlor鈥� 鈥� whether there were multiple settlors 鈥� application of s 644 and s 645 Income Tax (Trading and Other Income) Act 2005 鈥� whether dividend or distribution taxable under s 383 Income Tax (Trading and Other Income) Act 2005 鈥� whether taxpayer subject to tax by reference to the income of the settlement under transfer of assets abroad regime 鈥� chapter 2 Part 13 Income Tax Act 2007
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Published 24 November 2021