| Source: | All England Reporter |
| Publisher Citation: | [2003] All ER (D) 295 (Mar) |
| Neutral Citation: | [2003] EWCA Civ 356 |
| Court: | Court of Appeal, Civil Division |
| Judge: | Schiemann, Mummery and Dyson LJJ |
| Representation | David Ewart (instructed by Howes Percival) for the trustee. |
| Hugh McKay (instructed by the Solicitor of Inland Revenue) for the commissioners. | |
| Judgment Dates: | 20 March 2003 |
Catchwords
Inheritance taxation - Settlement - Settlor executing five trust deeds - Each of five trust deeds constituting separate settlement for inheritance tax purposes - s 43.
The Case
Applying the provisions of s43 of the in their ordinary and natural sense, each of five trust deeds executed by the taxpayers was to be taken to be a 'settlement' for the purposes of the 1984 Act, because each of them satisfied the definition of 'settlement' in s43(2)(b).
Practice Areas
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