Mr Theodore Wallace, Mr TG Coutts QC and Mr Gordon Reid QC sitting in Edinburgh.

Decision released 22 September 1997.

Income tax – Computation of profits – Taxpayer was insurance agent receiving commission – Full initial commission dependent on policies being maintained for several years – Half of commission advanced on terms that repayment if policies not maintained – Whether full advances charged to tax – Appeal dismissed.


The issue was the method of calculating commission paid to an insurance agent.

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