In Professor AK Halpin v HMRC (TC01359 – 22 August) a professor (H) did not declare any interest on his 2006/07 return although interest of more than £5 000 had been credited to a joint account held by H and his wife.
HMRC issued an assessment on the basis that 50% of the interest credited to the account was assessable on H.
He appealed contending that none of the interest should be taxed until it had been withdrawn by one of the account-holders.
The First-tier Tribunal rejected this contention and dismissed the appeal.
Judge Clark held that the effect of ITTOIA 2005 s 370 was that tax was charged on ‘the full amount of interest arising in the tax year’ and that ‘interest arises when it is credited to an account’.
Therefore the interest...
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In Professor AK Halpin v HMRC (TC01359 – 22 August) a professor (H) did not declare any interest on his 2006/07 return although interest of more than £5 000 had been credited to a joint account held by H and his wife.
HMRC issued an assessment on the basis that 50% of the interest credited to the account was assessable on H.
He appealed contending that none of the interest should be taxed until it had been withdrawn by one of the account-holders.
The First-tier Tribunal rejected this contention and dismissed the appeal.
Judge Clark held that the effect of ITTOIA 2005 s 370 was that tax was charged on ‘the full amount of interest arising in the tax year’ and that ‘interest arises when it is credited to an account’.
Therefore the interest...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
