Privy Council Wellington
18, 19, 20 January; 1 March 1993
Lord Keith of Kinkel, Lord Templeman, Lord Jauncey of Tullichettle, Lord Browne-Wilkinson and Lord Mustill
18, 19, 20 January; 1 March 1993
Lord Keith of Kinkel, Lord Templeman, Lord Jauncey of Tullichettle, Lord Browne-Wilkinson and Lord Mustill
Revenue — Income tax — Assignment of share of partnership — Income of partner derived from personal services or exertion — Whether partner able to assign income thus derived — Whether assignment of revenue producing income of a capital nature — Whether taxpayer by way of assignment able to escape assessment of tax from personal exertion — Tax avoidance — Partnership Act 1908, s 344 - Income Tax Act 1976, ss 10, 38(2) and 99.
Partnership — Professional partnership — Taxpayer partner in accountancy firm — Nature of proprietary interest in assets of accountancy partnership — Whether such interest assignable — Partnership Act 1908, s 34.
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