Court of Appeal (Civil Division).

Judgment delivered 31 July 1986.

Corporation tax – Close company – Annual payments to charity under covenant – Apportionment – Judicial review – Whether tax inspector under duty to apportion among its participators all covenanted payments to charity made by company – Whether discretion to make such apportionment – Finance Act 1972, Sch. 16, para. 3.

  This was an appeal by the taxpayer company against the decision of Peter Gibson J. (reported at [1986] BTC 92) whereby he ordered that notices of apportionment served on the taxpayer company in respect of covenanted payments to charity be quashed.

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