Inland Revenue Commissioners v British Salmson Aero Engines Ltd: CA 1938

The court considered the applicability of certain provisions to royalty payments. The court considered the notorious difficulty of drawing a clear line between capital and income receipts: ‘There have been many cases which fall on the border-line. Indeed, in many cases it is almost true that the spin of a coin would decide the matter almost as satisfactorily as an attempt to find reasons. But that class of questions is a notorious one, and has been so for many years.’


Sir Wilfrid Greene MR


[1938] 2 KB 482


England and Wales

Cited by:

CitedAtkinson (HM Inspector of Taxes) v Camas Plc CA 6-May-2004
An investment company made an abortive attempt to take over another. It sought to set off against its Corporation Tax, the costs of the professional advice incurred.
Held: The expenses were deductible. . .
Lists of cited by and citing cases may be incomplete.

Income Tax

Updated: 05 August 2022; Ref: scu.198423