Contractual land-tax allocation includes a special-purpose statutory levy directly charged on land, despite its limited area and purpose.

The lease and later memoranda were construed together against the fiscal history of New South Wales to determine whether a bridge levy fell within the contractual expression "land-tax". The wording extended the lessors' burden to any future land-tax or municipal tax on unimproved capital value, and a statutory impost directly charged on land was held to remain a land-tax even if confined to a particular area or imposed for a special public purpose. On that construction, the levy was within the covenant and the lessees were not liable to bear it; the challenge failed.

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Issues: Whether the lessees were liable under the lease and memoranda to bear the Sydney Harbour Bridge tax as a future land-tax or municipal-tax upon unimproved capital value, and whether that impost fell within the contractual expression "land-tax".

Analysis: The lease and the later memoranda were construed together in the light of the fiscal history of New South Wales. The later memorandum used broad language, extending the lessors' burden beyond the land-tax then assessed to "any future land-tax or Municipal-tax upon the unimproved capital value". On that construction, the decisive question was whether the bridge levy, though confined to a defined area and earmarked for a particular public work, was nevertheless a land-tax. A tax imposed directly by the Legislature on land was held to answer that description, and the limited area or special purpose of the impost did not change its essential character.

Conclusion: The bridge levy was within the expression "land-tax", and the lessees were not liable to pay it under the covenant; the appeal failed and the lessors' challenge was rejected.

Ratio Decidendi: A statutory impost directly charged on land remains a land-tax for the purpose of contractual allocation of tax liability, even if it is confined to a particular area or imposed for a special public purpose.

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