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PC decision
Attorney-General of British Columbia v. Kingcome Navigation Co. Ltd., [1928-34] CTC 215
As has already been pointed out the ultimate incidence of the tax, in the sense of the political economist, is to be dis- regarded, but where the tax is imposed in respect of a transaction, the taxing authority is indifferent as to which of the parties to the transaction ultimately bears the burden, and, as Mill expresses it, it is not intended as a peculiar contribution upon the particular party selected to pay the tax. ...