The point in this case was whether the Society was liable to be assessed in respect of interest, dividends, and rents, arising from investments in foreign countries.

The Society had large funds invested in various forms in foreign countries, in some of which countries the Society carried on the business of Life Assurance, and in others of which it carried on no business of any kind. It was admitted that only a part of the income arising from these investments was remitted to Great Britain, the rest of such income being either reinvested or remitted direct to other foreign countries for investment, or applied in payment of establishment and other expenses in the country where the interest was earned, or remitted direct to other foreign countries for the general purposes of the Society.