[2004] EWHC 1811 (Ch).

Chancery Division.

[The appeal against this decision is reported at [2005] BTC 392.]

Lewison J.

Judgment delivered 23 July 2004.

Income tax – Relief – Pensions – Retirement annuity contract – Unused tax relief – Taxpayer challenged Revenueʼs refusal of her method of utilising unused relief for pension contributions in any year – Whether unused relief from past years taken into account and aggregated – Whether personal pension contributions paid in current year deductible from aggregate – Income and Corporation Taxes Act 1988, s. 619, 625, 639, 655(1).

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