LORD MANTON’S TRUSTEES v STEELE (H.M. INSPECTOR OF TAXES).(1)STEELE (H.M. INSPECTOR OF TAXES) v LORD MANTON’S TRUSTEES.(1) (1926-27) 11 TC 549
No. 608.–HIGH COURT OF JUSTICE (KING’S BENCH DIVISION).–
25TH NOVEMBER, 1926.
COURT OF APPEAL.–
2ND AND 3RD FEBRUARY, 1927.
Income Tax – Foreign income – Interest on personal loan – Whether income from foreign security or foreign possession – Basis of assessment – Income Tax Act, 1918 (8 & 9 Geo. V, c. 40), Schedule D, Cases IV and V.
By an agreement in writing dated 9th August, 1919, Lord Manton lent personally to a Dutch company £1,500,000 repayable in London with interest at 6 per cent. by the following instalments:–