Mclarens Lubricants Limited vs Commissioner General of Inland Revenue – CA TAX/0038/2014-2022

In the case between McLarens Lubricants Limited and the Commissioner General of Inland Revenue, the court addressed whether profits derived from sales of lubricants to non-resident ships, supplied out of bonded warehouses, amounted to “qualified export profits and income” under Section 51 or, in the alternative, constituted “profits from the export of petroleum products” under Section 42(1) of the Inland Revenue Act No. 10 of 2006. The court held that such sales did not qualify as exports for the purposes of tax exemption, reaffirming the principle that tax exemptions must be clearly substantiated by the taxpayer with adequate evidence, particularly through documentary proof of export to a foreign destination. This decision was anchored in the interpretive principles for tax legislation, s