Inland Revenue Commissioners v Ayrshire Employers Mutual Insurance Association Ltd

[1946] 1 All ER 637

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(Decision by: Lord Wright)

Between: Inland Revenue Commissioners
And: Ayrshire Employers Mutual Insurance Association Ltd

Court:

Judges: Lord Thankerton
Lord MacMillan

Lord WrightLord Simonds
Lord Uthwatt

Subject References:
taxation
Other Taxation
Income Tax
Mutual insurance association
Surplus arising from transactions with members
Whether assessable

Legislative References:
Finance Act, 1933 (c 19) - s 31(1)

Case References:
New York Life Insurance Co v Styles - (1889), 14 App Cas 381; 28 Digest 59, 300; 59 LJQB 291; 61 LT 201; sub nom Styles v New York Life Insurance Co 2 Tax Cas 460
Municipal Mutual Insurance Ltd v Hills - (1932), 147 LT 62; Digest Supp; 16 Tax Cas 430

Hearing date: 25 February 1946
Judgment date: 29 March 1946

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Decision by:
Lord Wright

(read by Lord Thankerton) My Lords, I do not feel that I can add anything to the brilliant and incisive judgment of the Lord President (Normand) with which I am in complete agreement. His logic is unanswerable. I can see no escape from the conclusion at which he has arrived. The appeal should, in my opinion be dismissed.