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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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Particular Trades: mutual concerns: mutuality

Cases that deal with the concept of mutuality are

  • Styles v New York Life Assurance Co (1889) 2TC460 – see BIM24027
  • Thomas v Richard Evans & Co Ltd and Jones v The South West Lancashire Coal Owners’ Association Ltd (1927) 11TC790 – see BIM25115
  • Municipal Mutual Insurance Ltd v Hills (1932) 16TC430 – see BIM25105
  • Faulconbridge v National Employers’ Mutual General Insurance Association Ltd (1952) 33TC103 – see BIM24105.

Payments or receipts from a mutual concern to a person who carries on a trade, profession or vocation are dealt with at BIM24555 to BIM24620.

Refer any important cases where there is a large amount of tax involved or difficult issues, including any case where it is argued that a trade is partly mutual and partly not, to CTIS (Technical).

An up to date copy of the body’s constitutional documents (articles or rules) and copies of any contracts or agreements that deal with transactions with members should accompany the reference.