• I was interested in the note 'What is a covenant?' on page 687 of THE LIFE- BOAT for September, 1969. It implies that unless the payer suffers tax at the full rate the covenant is not applicable, whereas as I understand the position a person who pays tax at a reduced rate may covenant, in which case he will have to account to the Revenue for the difference between the highest tax he suffers and the standard rate. It is not difficult to calculate the amount of the covenant so that the amount paid under the covenant and the additional tax paid to the Revenue together equal the amount which the payer wishes to give.

Richard A. Holland, Holmes, Campbell & Co., Solicitors, Arundel, Sussex..