https://www.taxtmi.com/caselaws?id=184064 For taxation of a non-resident merchanting trade, the locality of the trade depends on where the substantive trading operations occur, not merely where the master arrangement was made. Because orders were received in England, goods were appropriated or manufactured there, delivery took place there, and payment was received there, the trade was exercised within the United Kingdom. The domestic company's standing arrangements, under which it held goods at the foreign company's disposal, sold only to approved customers on the foreign company's terms, and accounted for proceeds less cost and commission, were sufficient to support agency. The foreign company was therefore taxable on the basis that its trade was carried on in the United Kingdom through the English company as its agent. en-us Thu, 14 Feb 1957 00:00:00 +0530 Tue, 28 Jun 2016 18:03:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=184064 For taxation of a non-resident merchanting trade, the locality of the trade depends on where the substantive trading operations occur, not merely where the master arrangement was made. Because orders were received in England, goods were appropriated or manufactured there, delivery took place there, and payment was received there, the trade was exercised within the United Kingdom. The domestic company's standing arrangements, under which it held goods at the foreign company's disposal, sold only to approved customers on the foreign company's terms, and accounted for proceeds less cost and commission, were sufficient to support agency. The foreign company was therefore taxable on the basis that its trade was carried on in the United Kingdom through the English company as its agent. Case-Laws Income Tax Thu, 14 Feb 1957 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=184064