Trust Union Shipping Corporation v. Commissioner General of Inland Revenue – sllr 2003 volume 3 page 043

In the case between Trust Union Shipping Corporation and Commissioner General of Inland Revenue, the court addressed the issue of whether ships owned by a non-resident entity, but operated extensively in Sri Lankan waters under contract, constitute “property in Sri Lanka” for the purposes of the Inland Revenue Act No. 28 of 1979. It was held that such ships, though classified as movable property and registered outside Sri Lanka, are encompassed within the statutory definition of property in Sri Lanka when they generate profits from local activities. This decision reaffirmed the principle that the statutory framework does not require a “permanent nexus” for property to fall within Sri Lankan tax jurisdiction if profits are derived from operations within Sri Lanka. Reference was made to rele