Indeterminate member shares trigger taxation of the association's total income at the maximum marginal rate.

Tax is charged on the total income of an association of persons (other than a company or co-operative society) at the maximum marginal rate where individual member shares in the whole or any part of that income are indeterminate or unknown; the Explanation ties maximum marginal rate to the meaning in the Explanation to sub-section (3) of section 164 and deems shares indeterminate if unknown at formation or at any time thereafter.

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