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    <title>1947 (3) TMI 24 - HOUSE OF LORDS</title>
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    <description>A charging rule that taxes a deemed or notional profit computed by a prescribed statutory formula is not affected by the presence of investment income that is otherwise exempt from tax. The rule in issue applied a conventional basis of charge to the life assurance fund of a non-resident assurance company and treated a fixed fraction of total fund income as profits. Exemption provisions relating to actual investment income did not displace that self-contained computation, and the only express adjustment allowed was the statutory set-off where tax had already been borne independently. Exempt investment income therefore did not require any further reduction in the assessment.</description>
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    <pubDate>Mon, 31 Mar 1947 00:00:00 +0530</pubDate>
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      <title>1947 (3) TMI 24 - HOUSE OF LORDS</title>
      <link>https://www.taxtmi.com/caselaws?id=181581</link>
      <description>A charging rule that taxes a deemed or notional profit computed by a prescribed statutory formula is not affected by the presence of investment income that is otherwise exempt from tax. The rule in issue applied a conventional basis of charge to the life assurance fund of a non-resident assurance company and treated a fixed fraction of total fund income as profits. Exemption provisions relating to actual investment income did not displace that self-contained computation, and the only express adjustment allowed was the statutory set-off where tax had already been borne independently. Exempt investment income therefore did not require any further reduction in the assessment.</description>
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      <pubDate>Mon, 31 Mar 1947 00:00:00 +0530</pubDate>
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