156. Meaning of 'annual payments'.

In the statutory provisions relating to deduction of tax1, the words 'or other annual payment' are to be construed ejusdem generis with 'interest'2 and 'annuity'3. Thus instalments of a capital sum, although payable at intervals of a year, are not annual payments within the Tax Acts4, but the consideration for a sale may take the form of annual payments of an income nature5. In certain circumstances it is possible to dissect the payment into capital and income elements6.

Rent is not, as such, an annual payment within these provisions7, but the consideration for a letting may consist of a series