The Law Reports (Appeal Cases)
[1962] AC 135
[PRIVY COUNCIL]
AUSTRALIAN MUTUAL PROVIDENT SOCIETY APPELLANTS; AND COMMISSIONER OF INLAND REVENUE RESPONDENT.
ON APPEAL FROM THE SUPREME COURT OF NEW ZEALAND.
1961 Nov. 20.
VISCOUNT KILMUIR L.C., LORD DENNING, LORD MORRIS OF BORTH-Y-GEST, LORD HODSON and LORD DEVLIN
New Zealand
— Revenue
— Income tax
— Life assurance
— Mutual life insurance society
— Statutory definition of profits
— Society assessable on surplus funds allotted to participating policyholders as reversionary bonuses
— Deduction of income of society “exempt from taxation”
— Differing methods of calculating amount of surplus funds required to meet present cash value of reversionary bonuses -
136
Concurrent findings on question of fact
— Income “exempt from taxation” limited to income taxable under New Zealand tax laws
—
Land and Income Tax Act, 1954, of New Zealand (No. 67 of 1954), ss. 86 (1) (i), 149 (1) (2).
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