Access International (Private) Limited vs. The Commissioner General of Inland Revenue – CA TAX/0016/2018-2022

In the case between Access International (Private) Limited (Appellant) and The Commissioner General of Inland Revenue (Respondent), the court addressed whether the Appellant, a Sri Lankan resident company, was entitled to claim a tax exemption under section 13 (dddd) of the Inland Revenue Act, No. 10 of 2006, on commission income earned in foreign currency for services rendered to companies principally outside Sri Lanka, particularly Mabey & Johnson Ltd, UK. The decision held that the legislative requirements for exemption were met, clarifying that the existence of a local branch did not automatically constitute a “permanent establishment” to bar exemption, and the services in question were indeed rendered to foreign companies. Reliance was placed on statutory interpretation, relevant cont