8 Jul 2011
AVIATION FUEL SUPPLY CO v. COMMISSIONER OF INLAND REVENUE
- Citation
- AVIATION FUEL SUPPLY CO v. COMMISSIONER OF INLAND REVENUE
- Court
- Court of First Instance
- Case number
- HCIA6/2009
AFSC's business was properly characterised as owning and exploiting the Facility to derive Facility Payments; the Sum formed part of an Accelerated Facility Cost Payment that sterilised AFSC's future income stream and was therefore capital in nature and not chargeable under s14; alternatively s15A did not render the Sum taxable because there was no relevant transfer of a right to receive income to the Authority in the statutory sense or, if there was, the transfer was accompanied by transfer of the property (the Facility) so that s15A(3) applied.