Hugh Murphy & Anor. v The Commissioners for HMRC
ESC B18 (1999) does not impose a six-year income limit on credit claims by UK beneficiaries of non-resident trusts; the concession is not ambiguous or qualified in this respect, and the relevant conditions are those expressly stated in the section relating to UK beneficiaries of non-resident trusts.
Source excerpt
- Extra-statutory concessions
- Trust taxation
- Legitimate expectation
- Interpretation of administrative policy