INCOME TAX CASE

New Zealand Herald, Volume LXXV, Issue 22982, 9 March 1938, Page 16

INCOME TAX CASE

HOUSE OF LORDS APPEAL NEW ZEALAND OPERATIONS [fbom ouh own correspondent] LONDON, Feb. 19 The National Mortgage and Agency Company of New Zealand, Limited, was respondent in an appeal which occupied the attention of the House of Lords for several days during the past week. The appeal was brought by the British Inland Revenue Department. Although incorporated and controlled in Britain the company's business is chiefly in New Zealand., and the point at issue was the amount of United Kingdom income tax relief the firm was entitled to because of tax paid in the Dominion. The company had claimed relief under a number of heads. One of these related to tax paid in New Zealand on debenture interest. The company maintained that it was entitled to relief 011 this as it was a payment in respect of the company's income, whereas the Crown claimed that it was a payment in respect of the debenture-holders' income. The decision of the special, commissioner, to whom the case was first referred, was in the main in favour of the company. His ruling was reversed when an appeal was made to the High Court, but this decision was again reversed by the Court of Appeal. After a lengthy hearing the Houso of Lords reserved judgment.