References: T1085/8/40, ROL/VMJ
Cambridge University Press.
Secretary, Taxes.
I have noted the Special Commissioners' decision.
In head (2) on the first page of his Report of the hearing the Solicitor remarks, "apparently it has already been agreed that profits on this work should be exempt." No such agreement had been made by this Office. It is possible the remark was caused by a paragraph 8 of the note of interview dated 25th January, 1940. As is indicated by the last phrase of that paragraph and by the letter of the 26th January, 1940, confirming the result of the interview, no agreement was reached that the profits from printing for the University should be exempted. The argument for the Revenue was that while a small part of the claimant's trade might be regarded as having been exercised in the course of the actual carrying out of a primary purpose of the charity, the greater part of it could not be so regarded, and in consequence the whole claim must fail. This appears to be also the result of the Special Commissioners' decision, but it is possible that the point had been given away in the course of the hearing.