https://www.taxtmi.com/caselaws?id=276116 For relief against double taxation under section 27 of the Finance Act, 1920, the comparison is between the statutory incomes from the same source in the two jurisdictions, and the constituent allowances or special exemptions used in computing those incomes are not separately dissected. A New Zealand special exemption therefore could not be deducted from the United Kingdom comparative income. Debenture interest taxed in New Zealand in the company's hands as agent for debenture holders was also included in the New Zealand comparative income because the tax was actually borne by the company in substance and could not be passed on. Relief was accordingly worked out on that basis, without treating the agency label as decisive. en-us Mon, 07 Feb 1938 00:00:00 +0530 Tue, 30 Oct 2018 12:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276116 For relief against double taxation under section 27 of the Finance Act, 1920, the comparison is between the statutory incomes from the same source in the two jurisdictions, and the constituent allowances or special exemptions used in computing those incomes are not separately dissected. A New Zealand special exemption therefore could not be deducted from the United Kingdom comparative income. Debenture interest taxed in New Zealand in the company's hands as agent for debenture holders was also included in the New Zealand comparative income because the tax was actually borne by the company in substance and could not be passed on. Relief was accordingly worked out on that basis, without treating the agency label as decisive. Case-Laws Income Tax Mon, 07 Feb 1938 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276116