17 Oct 2006
COMMISSIONER OF INLAND REVENUE v. ELLIOTT, STEWART WILLIAM GEORGE
- Citation
- COMMISSIONER OF INLAND REVENUE v. ELLIOTT, STEWART WILLIAM GEORGE
- Court
- Court of Appeal
- Case number
- CACV286/2006
On construction of the agreements the US$11,000,000 was paid to extinguish the whole bundle of contractual ICP rights (existing and future, including contingent pro rata entitlements) and therefore constituted compensation for loss of contractual rights rather than remuneration for services; accordingly the sum was not chargeable to salaries tax and apportionment to isolate a taxable inducement was unnecessary and unjustified.