Many of the cases referred to below concern payments of interest which, for periods before the introduction of the loan relationships rules, were largely deductible on a paid basis. These cases are, in most cases, no longer relevant to interest payments but should continue to apply to any tax reliefs which require expenditure to be paid, e.g. relief for qualifying charitable donations.

In Eyles v Ellis (1827) 4 Bing 112, the defendant instructed his bank to transfer funds from his account to that of the plaintiff: the transfer in the bank’s books was regarded as payment of the sum in point by the defendant to the plaintiff.

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