91.   The term system is used here to denote any set of related elements where elements may be physical objects, abstract entities or human beings.

92.   There should be no element of double charge when the manager disposes of his shares because the notional loan element should not also be liable to capital gains tax.

93.   But even here there may be elements of uncertainty.

94.   However, in many instances there will also be an element of damages for personal injuries of varying severity.

95.   It is difficult to prevent the creation of a settlement, although there cannot be a settlement unless there is an element of bounty.

96.   The taxpayer contended that it was necessary, before the Revenue could succeed, for the Revenue to show that there was an element of bounty.

97.   In my opinion the true rule is that the definition applies only where there is an element of bounty.

98.   The Revenue contended that there was an element of bounty because there was no obligation upon the company to pay interest.

99.   The Special Commissioners found as a fact that there was no element of bounty with regard to the loan.

100.   If Mr X gives property to his settlement there will clearly have been an element of bounty.