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    <title>1943 (12) TMI 8 - HOUSE OF LORDS</title>
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    <description>Section 18 of the Finance Act, 1936 was discussed as an anti-avoidance provision aimed at transfers of assets that diverted income outside the United Kingdom. The text explains that the transferred assets must be read together with associated operations, and that partnership profits can still be income &quot;payable&quot; within the section because a partner may enforce payment through the partnership machinery and the undrawn share can appear as a debt in the accounts. On the facts described, the arrangement was treated as an artificial scheme designed to divert profits while avoiding British income-tax and surtax, and the provision was applied broadly to catch it.</description>
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    <pubDate>Wed, 08 Dec 1943 00:00:00 +0630</pubDate>
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      <title>1943 (12) TMI 8 - HOUSE OF LORDS</title>
      <link>https://www.taxtmi.com/caselaws?id=183394</link>
      <description>Section 18 of the Finance Act, 1936 was discussed as an anti-avoidance provision aimed at transfers of assets that diverted income outside the United Kingdom. The text explains that the transferred assets must be read together with associated operations, and that partnership profits can still be income &quot;payable&quot; within the section because a partner may enforce payment through the partnership machinery and the undrawn share can appear as a debt in the accounts. On the facts described, the arrangement was treated as an artificial scheme designed to divert profits while avoiding British income-tax and surtax, and the provision was applied broadly to catch it.</description>
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      <pubDate>Wed, 08 Dec 1943 00:00:00 +0630</pubDate>
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