17 Dec 2013
SOVEREIGN ASSURANCE COMPANY LIMITED & ORS V COMMISSIONER OF INLAND REVENUE CA506/2012 [2013] NZCA 652
- Citation
- [2013] NZCA 652
- Court
- Court of Appeal
The accruals rules governed the commission cash flows; the commission payments were advances/loans (financing) not earned insurance income, no property or transfer of cash flows occurred for s EH 10(2), and consequently the base component was capital in character (non-assessable as income and non-deductible on repayment) while only the excess/interest component was deductible under the accruals regime.