Chancery Division.

[The appeal against this decision is reported at [1995] BTC 406.]

Vinelott J.

Judgment delivered 7 March 1994.

Corporation tax – Annual payment – Covenant in favour of charity – Mistake in covenant resulting in annual payments lasting less than three years – Payments thus not constituting charge on income nor income of charity – Whether court would rectify deed of covenant – Income and Corporation Taxes Act 1988, s. 399(8), 660(1)(3).

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