Covenanted payments
Benefit of children, deed of separation a settlement
Non-competition, capital sum derived from asset
Case Law –
Kirby (H.M. Inspector of Taxes) v. Thorn EMI plc. [1987] BTC 462
;
Kirby (H.M.I.T.) v. Thorn EMI plc. [1986] BTC 160
Pure income profit constituting annual payments