ABSTRACT

The main provisions of Schedule D Case III charges tax in respect of ‘any interest of money, whether yearly or otherwise, annuities and other annual payments’.

‘Interest’ has been defined as the payment by time for the use of money, per Rowlatt J in Bennett v Ogston (1930). It is sometimes a difficult question to distinguish ‘interest’ from ‘capital’, for example, payment of a sum above a reasonable commercial rate of interest.