Court of Session (Inner House).

Lord Johnston, Lord Kirkwood and Lord Caplan.

Judgment delivered 31 July 1998.

Income tax – Sch. D – Foreign pensions – Taxpayers in receipt of US and French retirement pension payments – Payments as a result of contributions from taxed income – Whether liable to UK tax – Income and Corporation Taxes Act 1988, s. 18.

  This was an appeal by the taxpayers, Dr Albon and his wife, against a decision of a special commissioner that pension payments made to them by the US and the French governments were taxable under Case V of Sch. D.

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