Rodrigo v. The Commissioner General of Inland Revenue – sllr 2002 volume 1 page 384

In the case between Rodrigo (Appellant) and the Commissioner-General of Inland Revenue (Respondent), the court addressed the issue of whether fees earned in foreign currency by a partnership rendering professional services are exempt from income tax under section 15 (ccc) of the Inland Revenue Act, and whether related business expenses could be disallowed on a pro rata basis when determining divisible profits. It was held that such foreign currency earnings, while exempt under statute, do not justify the allocation of business expenses on a proportional basis between taxable and exempt income when the business is operated as a single indivisible entity. The legal principle reaffirmed was that expenses from an indivisible business should not be apportioned between its local and foreign sour