Chapter TSEM8230

Published date02 May 2016
Record NumberTSEM8230

ITA/S484 provides for relief for trust management expenses that are ‘properly chargeable to income, ignoring the express terms of the settlement’. This is taken from the original wording in ICTA88/S686(2AA) ‘properly chargeable to income (or would be so chargeable but for any express provisions of the trust)’. The full meaning of this is explained in Carver v Duncan, when Lord Templeman examined the tax law question of the deductibility of expenses for the purpose of calculating income chargeable under what is now ITA/S479.

In that case, the...

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