Notional interest on buyer advances is includible in assessable value when sale price is not the sole consideration.

Notional interest arising from interest-free advances taken from buyers was treated as part of the assessable value because the advances secured the buyers' commitments and were linked to the sale transaction. The declared contracted price did not exclude the extra commercial advantage obtained by the manufacturer where the price was not the sole consideration passing directly or indirectly from the buyer. On that reasoning, the monetary benefit from the interest-free advances was includible in valuation, and additional consideration of that kind forms part of assessable value when it accompanies the sale.

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Issues: Whether notional interest on interest-free advances taken from buyers formed part of the assessable value of the goods.

Analysis: The advances were taken to secure performance of the buyers' commitments and were linked to the sale transaction. The price being a contracted price did not, by itself, exclude the value of the extra commercial advantage flowing from the interest-free advances. Where the price is not the sole consideration flowing directly or indirectly from the buyer to the manufacturer, the additional monetary value of such consideration is includible in the price for valuation purposes.

Conclusion: Notional interest on the advances was includible in the assessable value.

Final Conclusion: The challenge to inclusion of notional interest in valuation failed and the appeals were dismissed.

Ratio Decidendi: Any additional consideration, including the monetary benefit arising from interest-free advances, is includible in assessable value where the declared price is not the sole consideration for the sale.

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