United Kingdom House of Lords Decisions

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URL: http://www.bailii.org/uk/cases/UKHL/1979/TC_54_503.html
Cite as: [1979] TR 381, [1980] AC 1148, [1979] 3 WLR 915, [1980] STC 10, [1979] UKHL TC_54_503, 54 TC 503, [1979] 3 All ER 976

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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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