Robert Venables QC and Rory Mullan (instructed by Deloitte & Touche LLP, chartered accountants) for the trustees.
Assessment – Income of trust – Special rates of tax – Shares in company comprising settled property of trust – Settlor making cash contribution to company but retaining no rights – Company offering shareholders option to receive more shares instead of cash dividend – Trustees electing to receive the dividend of further shares in company – Whether dividends paid to trustees were taxable at the higher Sch F trust rate – Income and Corporation Taxes Act 1988, ss 249(6), 686(1).