Court of Appeal Wellington
21, 22, 23 May; 16 July 1973
McCarthy, Richmond and White JJ
21, 22, 23 May; 16 July 1973
McCarthy, Richmond and White JJ
Income tax — Interpretation — Objection to assessments — Double taxation relief — UK company having subsidiary NZ company — Taxed pursuant to cl 4(1)(b) of Part A and Part C of First Schedule and not cl 4(1)(a) of Part A and Part B of First Schedule — Proprietary tax properly assessed on UK company — Land and Income Tax Act 1954, ss 138, 172, First Schedule, Part A, cl 4(1)(a) and (b) — Double Taxation Relief (United Kingdom) Order 1966 (SR 1966/119), Schedule, Articles III(I), XIX(I).
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