In March, 1921, an award was made by the Royal Commission on Awards to Inventors in respect of the user, past, present and future, by the British Government (including user by way of selling for use, licensing or otherwise) of the Mills bomb. Over 75 millions of these bombs had been made during the war and large stocks were still in existence. The Appellant, as patentee of certain improvements to this bomb, received sums representing the major part of this award, and was charged to Income Tax thereon. The General Commissioners, on appeal, held that in view of the large stock of bombs still in existence further manufacture during the currency of the Appellant’s patents was unlikely, and that the amount of the award attributable to future user was negligible, and they decided that the sums received by the Appellant were annual profits or gains chargeable to Income Tax under Schedule D.
Citations:
[1929] UKHL TC – 14 – 769
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 09 November 2022; Ref: scu.649132