In A & Mrs G Pope v HMRC (Upper Tribunal – 27 June) a geologist (P) was kidnapped in Angola in 1998 and was never seen or heard from again. He had taken out a life insurance policy and in 2002 the insurers paid his parents £100 000 under the policy plus a further £36 425 which was described as interest. HMRC issued a ruling that the £36 425 was subject to income tax and chargeable on P’s parents. P’s parents appealed contending firstly that the payment should be treated as exempt under what is now ITTOIA 2005 s 751 and alternatively that they were not the ‘person receiving or entitled to the interest’ within what is now ITTOIA 2005 s 371. The Upper Tribunal rejected the first contention holding that the payment failed to qualify for exemption under s 751 but...
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In A & Mrs G Pope v HMRC (Upper Tribunal – 27 June) a geologist (P) was kidnapped in Angola in 1998 and was never seen or heard from again. He had taken out a life insurance policy and in 2002 the insurers paid his parents £100 000 under the policy plus a further £36 425 which was described as interest. HMRC issued a ruling that the £36 425 was subject to income tax and chargeable on P’s parents. P’s parents appealed contending firstly that the payment should be treated as exempt under what is now ITTOIA 2005 s 751 and alternatively that they were not the ‘person receiving or entitled to the interest’ within what is now ITTOIA 2005 s 371. The Upper Tribunal rejected the first contention holding that the payment failed to qualify for exemption under s 751 but...
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