Smart v. Lincolnshire Sugar Co., Ltd. (1937), 20 TC 643 (HL) -- summary under Compensation Payments

The taxpayer, which already was entitled to receive annual subsidies in respect of every hundredweight of sugar or molasses manufactured during the 10-year period commencing 1 October 1924 from beets grown in Great Britain, received in 1931 further "advances" pursuant to the British Sugar Industry (Assistance) Act, 1931, which provided that such advances would be repayable by way of set-off against the annual subsidies in the event that the market price of sugar exceeded specified levels (which, in fact, did not occur). Lord Macmillan stated (p. 670) that "these payments were made to the Company in order that the money might be used in their business", and that the payments accordingly should be regarded as supplementary trade receipts.