Chancery Division.

Vinelott J.

Judgment delivered 7 December 1990.

Income tax – Emoluments of employment – Avoidance scheme – Interest-free loan from employer to trustees of Jersey settlement for benefit of employee domiciled outside UK – Money deposited in Jersey bank and interest paid to employee – Whether trust income emolument from employment taxable under Sch. E or income from foreign possession taxable under Sch. D, Case V on a remittance basis.

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