Access International (Private) Limited v. The Commissioner General of Inland Revenue – CA TAX/0017/2018-2022

In the case between Access International (Private) Limited and the Commissioner General of Inland Revenue, the court addressed whether commission income earned by a Sri Lankan company for services rendered to foreign companies, specifically Mabey & Johnson Ltd, UK, qualifies for exemption from Sri Lankan income tax under Section 13 (dddd) of the Inland Revenue Act, No. 10 of 2006 (as amended), particularly where the foreign principal maintains a branch in Sri Lanka. It was held that such income is exempt, provided that services are rendered to a person or partnership outside Sri Lanka and statutory requirements are met, irrespective of the foreign company’s branch presence in Sri Lanka, unless business is actually conducted through that branch. The principle reaffirmed is that the exemptio