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HMRC internal manual

Trusts, Settlements and Estates Manual

HM Revenue & Customs
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Tax Cases: CIR v Plummer 54 TC 1


In a tax avoidance scheme an individual received a lump sum and in exchange made covenanted payments. He claimed a deduction for the payments in computing his total income.


The covenanted payments were income payments and the Settlements legislation did not apply to the arrangement. This is because the individual had received full consideration and there was no element of bounty.

TSEM references