Commentary

B5.230 Where freehold sold

Business tax
Business tax | Commentary

B5.230 Where freehold sold

Business tax | Commentary

B5.230 Where freehold sold

The earliest case was John Emery & Sons v IRC1, which arose in Scotland. A firm of builders acquired land, divided it into plots, and built houses on the plots. They created ground annuals over the houses and the plots and sold the houses and the plots for a cash payment, but retained the ground annuals. In this case it was held that the realisable value of the ground annuals, which were convertible into money at any time, should be added to the cash payments for the purpose of ascertaining the receipts of the firm for

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