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37 IRD’s Practice The IRD applies the Petrotim Securities
decision to extend the Sharkey v. Wernher
principle to cases where
The stock is disposed other than in the normal
course of trade.
Hence it is possible to apply this rule to cases Where a trader makes a sale at a very low
price to a member of his family or
price A trading transaction between associated
companies not at arm's length.
companies 38 Extension of Sharkey v Wernher Where the market value has been substituted
for the agreed sale price.
sale The purchaser's purchase price should be
substituted by the market value also for tax
purposes (Ridge Securities Ltd. v. CIR (1963)
44 TC 373).
44 39 Services The Sharkey v. Wernher
principle would not apply to
services rendered by
professionals (Mason v.
40 Change of Intention Where a trader transfers his current asset
to fixed asset, i.e., he has a change...
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- Spring '13