WAR-TIME PROFITS.

New Zealand Herald, Volume LXVI, Issue 20219, 2 April 1929, Page 7

WAR-TIME PROFITS.

TAXES PAID IN BRITAIN. JUDGMENT IN AUSTRALIA. Tlio Full ni-h Court of Australia lias ordered the Federal Commissioner of Taxation to refund £8564 to S. Hoffnurig and Company, Limited, of Sydney, and London, and to pay the costs of two appeals. Iloffnung and Company lodged appeals against assessments of war-time profits tax for tho financial years 1917, 1918 and 1919. The question at issue lelated to tho deduction to bo allowed for payment of excess profits duly under tho Imperial Finance Act. The company contended that the amount to be allowed was so much of the oxcess profits duty actually paid in Britain as was attributahlo to profits dorived from its Australian business, irrespective of any differences between the method adopted by the British revenue authorities and that prescribed by the War-time Profits Tax Assessment Act, for calculating the amount of taxable profits. It was submitted by the commissioner that the expression "profits" meant tho profits of the Australian business which remained after making all deductions allowed by the War-timo Profits Tax Assessment Act, and before making the deduction in respect of British duty. The Chief Justice, Sir Adrian Knox, said that the result of the commissioner's contention would be that, if, as in this case, the amount of the profits of the Australian business, after making such deductions, were less than tho amount of the Australian profits as determined by tho British revenue authorities, the taxpayer would bo entitled to a deduction of part, and not of the whole, of tho amount of excess profits duty paid by him in respect of Australian profits. This contention could not bo sustained.