Tax charge on association income applies at the maximum marginal rate, with portions taxed at higher member rates where applicable. Where members' shares in an association of persons or body of individuals are indeterminate or unknown, tax is charged on the association's total income at the maximum marginal rate, or at a higher rate if any member's personal tax rate exceeds that rate. Where shares are determinate, portions attributable to members chargeable at higher rates are taxed at those rates and the balance at the maximum marginal rate; shares are deemed indeterminate if indeterminate on formation or thereafter.
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Provisions expressly mentioned in the judgment/order text.
Tax charge on association income applies at the maximum marginal rate, with portions taxed at higher member rates where applicable.
Where members' shares in an association of persons or body of individuals are indeterminate or unknown, tax is charged on the association's total income at the maximum marginal rate, or at a higher rate if any member's personal tax rate exceeds that rate. Where shares are determinate, portions attributable to members chargeable at higher rates are taxed at those rates and the balance at the maximum marginal rate; shares are deemed indeterminate if indeterminate on formation or thereafter.
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