Summary British tax Acts in the middle of the eighteenth century said the tax year ran "from" 25 March. The use of the word
from is crucial, because the word has a special legal meaning that caused the tax year to begin one day later, namely, on
26 March (as explained at
§Legal rule, below). The taxes charged annually in the mid eighteenth century were
Land Tax and
Window Tax. The
Calendar (New Style) Act 1750 elided eleven days from September 1752 but, despite this elision, the Window Tax tax year continued to run "from" 25 March 1753 (
NS) until April 1758 when Parliament moved it to a year "from" 5 April. The Land Tax year never changed. In September 2021, the
Office of Tax Simplification published a report considering the benefits, costs and implications of moving the end of the tax year from 5 April to either 31 December or 31 March. It concluded that although there was popular support for moving the date, there were different opinions on which date was best and that any change would take some time to implement.
Legal rule When a document or statute said a period of time was to run 'from' a date, an old legal rule provided that the period began on the following day. This rule of interpretation dates back at least to Sir
Edward Coke's landmark work of 1628 called the
Institutes of the Lawes of England. Coke's book was written as a commentary on the 1481 treatise on property law by Sir Thomas Littleton. Hence the specialist use of "from" may originate much earlier than 1628. The key passage in the
Institutes is short: Coke's
Institutes were an important source of education for lawyers and editions were published up to the nineteenth century. This is why tax acts in the eighteenth century used "from" 25 March in an exclusive sense to mean a period beginning on the following day. Numerous court cases have arisen because the technical meaning of
from a date in acts and documents has been misunderstood. The Office of the Parliamentary Counsel, which drafts legislation today, has published online drafting guidance which says the
from a date formulation is ambiguous and should not be used. Perhaps the most important contemporary authority for the start of the Land Tax year is in
An Exposition of the Land Tax by Mark A Bourdin of the Inland Revenue which was published in 1854. In a footnote on page 34 he says: "the year of assessment is from 26th March to the 25 March following". Bourdin does not use
from in the strict sense required by Coke but it is clear that he believes the Land Tax year begins on 26 March and ends on the following 25 March. In 1798 William Pitt made Land Tax permanent with the
Land Tax Perpetuation Act 1798. Section 3, for example, refers to "an assessment made in the year
ending on the twenty fifth day of March 1799", which confirms the Land Tax year begins on 26 March. The Land Tax year remained essentially unchanged until the tax was abolished in 1963. A number of authorities explain why the old tax year began on 26 March so that the addition of eleven days led directly to the modern tax year which begins on 6 April.
Accounting convention Accounting practice from time immemorial also took the same view. A
quarter day, such as
Lady Day which falls on 25 March, marked the
end of an accounting period and not the beginning. This view is taken by leading authorities including
The Exchequer Year,
The Pipe Roll Society and Dr Robert Poole in two works. In the 1995 work
Calendar Reform Dr Poole cites Treasury Board Papers at the National Archives under reference T30 12 and explains that, after the omission of eleven days in September 1752, Treasury quarterly accounts carried on being drawn up to the same four
days but the
dates had moved on by eleven days. He says: These were the old
quarter days of 25 December, 25 March, 24 June and 29 September
plus eleven days. Dr Poole's analysis is confirmed by a minute of the Board of Customs on 19 September 1752, shortly after the omission of the eleven days 3 to 13 September 1752 and not long before the first quarter day affected by the omission—
Michaelmas 29 September 1752. The minute says:
Eleven days added to prevent loss of tax? Some commentators, such as Philip (1921), In fact the British tax authorities did
not add eleven days to the end of the tax year which
began on 26 March 1752. They did not need to add eleven days because the taxes charged by the year captured artificial, deemed income, and not actual income. For Land Tax, the more important of the two, the amounts taxed were fixed sums linked to the market rental value of property in 1692 when the tax was introduced. For
Window Tax it was so much per window. The same tax was due regardless of the year length. Window Tax was a permanent tax and its year did not change until 1758 when the tax was recast and the tax year moved by eleven days to run "from" 5 April. That meant a year which began on 6 April because of Sir Edward Coke's 1628 interpretation rule. The 1798 Act uses the standard "from" formula and says in section 2:
Income tax year William Pitt introduced the first
income tax in 1799, and followed the
Window Tax precedent by adopting a year which ran "from" 5 April. That meant, once again, a year which began on 6 April, and this has remained the start of the year ever since. For example, Addington's Income Tax Act 1803 continued to apply "from" 5 April—in this case from 5 April 1803. Again, this meant a year beginning on 6 April 1803. Income tax was repealed temporarily in 1802 during a brief period of peace in the long war with France. The act which repealed the tax included a provision which permitted the collection of tax due for earlier years. This saving provision confirmed that Pitt's income tax year ended on 5 April: It was not until 1860 that income tax legislation consistently adopted a charging formulation of the kind recommended today by the Office of the Parliamentary Counsel to identify the income tax year. For 1860–61 the tax was applied "for a year
commencing on 6 April 1860". [Emphasis added.] Section 48(3) of the
Taxes Management Act 1880 (
43 & 44 Vict. c. 19) later provided a definition of the income tax year for the first time and uses "from" in the modern sense: The relevant passage is short: Philip does not give any reason for his view and
Poole's analysis shows that it is incorrect. Philip does not cite any legislation or other authority. It is also worth noting that the "financial year" he mentions is
not the same as the income tax year. The financial year is statutorily defined by the Interpretation Act 1978 as the year which ends on
31 March. This repeats an earlier similar definition in section 22 Interpretation Act 1889. This is the year for government accounting and for corporation tax. Poole gives a simpler explanation: ==See also==