https://www.taxtmi.com/caselaws?id=176103 Rule 3 of Case III of Schedule D operated as a special statutory mechanism for attributing a notional proportion of a foreign life assurance company's world investment income to its United Kingdom business, rather than as a direct tax on specific investments or on business profits simpliciter. That attribution method was inconsistent with the United Kingdom-Australia Double Taxation Relief Agreement, because the treaty required profits of a foreign enterprise with a permanent establishment to be attributed on an arm's length basis. The rule 3 assessment could not therefore be sustained where the treaty displaced the unilateral domestic method of computation. en-us Thu, 04 Jun 1959 00:00:00 +0530 Sat, 12 Dec 2015 11:18:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=176103 Rule 3 of Case III of Schedule D operated as a special statutory mechanism for attributing a notional proportion of a foreign life assurance company's world investment income to its United Kingdom business, rather than as a direct tax on specific investments or on business profits simpliciter. That attribution method was inconsistent with the United Kingdom-Australia Double Taxation Relief Agreement, because the treaty required profits of a foreign enterprise with a permanent establishment to be attributed on an arm's length basis. The rule 3 assessment could not therefore be sustained where the treaty displaced the unilateral domestic method of computation. Case-Laws Income Tax Thu, 04 Jun 1959 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=176103