Chancery Division.

[The appeal against this decision is reported at [2000] BTC 64.]

Lightman J.

Judgment delivered 14 October 1998.

Income tax – Exemption – Pension scheme trustees – Sub-underwriting commissions – Whether sub-underwriting of share issues was taxable under Sch. D, Case I as a trade and not under Sch. D, Case VI – Whether exemption available – If trading, whether trustees liable to additional rate tax on certain income of discretionary trusts – Income and Corporation Taxes Act 1988, s. 592, 686.

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