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Ashton and Another v Commissioner of Inland Revenue - [1975] 2 NZLR 717


Privy Council Wellington
6, 7, May; 9 July 1975
Lord Diplock, Lord Morris of Borth-y-Gest, Viscount Dilhorne, Lord Kilbrandon and Lord Salmon
Income tax — Interpretation — Taxpayers diverting income to family trusts — Motive of taxpayer irrelevant but end achieved is decisive — Effect of annihilating transactions — Land and Income Tax Act 1954, s 108.
Contract — Interpretation — In ascertaining the intention of the parties it is not proper to have regard to their conduct after the contract has been made.

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