27 Nov 1998
RANON LTD. v. COMMISSIONER OF INLAND REVENUE
- Citation
- RANON LTD. v. COMMISSIONER OF INLAND REVENUE
- Court
- Court of First Instance
- Case number
- HCIA4/1998
The court held the Board was wrong: the interest capitalised in the companies' accounts had not previously been deducted for tax in the early years and therefore the appellants were entitled in principle to deduct interest under s.16(1)(a) for the relevant basis periods (with losses carried forward under s.19C(4)); commercial accounting treatment of capitalisation does not by itself constitute a prior tax deduction or bar the statutory deduction, subject to adjustment for any small capital portion identified as non-deductible.