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HMRC internal manual

Trusts, Settlements and Estates Manual

Tax Cases: Dale v CIR 34 TC 468


A will set up a company and various organisations, including a research fund and museum. The will provided for the trustees to receive £1,000 free of tax for the time they put into the company and the organisations. The duties took about 2 hours a day.


The income was earnings from an office or employment. It was not investment income.

TSEM references