An English assurance company, which carried on its business partly in foreign countries, invested its trading balances in the respective countries on the spot either as statutory deposits or to form a local reserve fund. The Crown claimed to tax the interest on such investments as profits within case 1 of Sched. D of the Income Tax Act 1842. The company claimed to be assessed only under case 4 in respect of sums actually received in Great Britain.
Held that the interest and dividends derived from the said investments irrespective of their object formed part of the company’s trading profit and were assessable under case 1 of Sched. D.
Earl Loreburn and Lords Shaw, Mersey, and Parker
[1913] UKHL 575, 51 SLR 575
Bailii
England and Wales
Income Tax
Updated: 26 January 2022; Ref: scu.632749
