17. General rules for interpretation of taxing Acts.

The normal canons of statutory construction apply to taxing Acts1, but in addition there are certain other considerations which may be regarded as special in the construction of such Acts. Thus, under the traditional approach to interpreting tax statutes it was a general principle of fiscal legislation that to be liable to tax the subject must fall clearly within the words of the charge imposing the tax, otherwise he would go free; and that it was for the Crown to establish that the charge prima facie extended to the subject matter sought to be charged2. Whether this strict rule