In a will made in the United Kingdom by a testator residing there, 'free of taxes' is assumed, in the absence of a contrary intention, to refer only to taxes imposed by the law of the United Kingdom1. Accordingly, a bequest free of all taxes (including income tax) has been held not to include income tax to which the annuitant was liable under the law of Kenya where she had gone to live after the testator's death2. However, where annuities3 were bequeathed clear of all deductions whatsoever, including income tax
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