Macoun v Commissioner of Taxation

Income tax – International Organisations (Privileges and Immunities) Act 1963 (Cth) – Exemption from taxation on salaries and emoluments received from certain international organisations – Whether monthly pension payments exempt from taxation.

International law – Treaty interpretation – Privileges and immunities of specialized agencies – Whether Convention on the Privileges and Immunities of the Specialized Agencies requires Australia not to tax monthly pension payments received by former officer of specialized agency.

Words and phrases – "emolument", "pension", "salary".

International Organisations (Privileges and Immunities) Act 1963 (Cth) – s 6(1)(d)(i), Fourth Schedule.

Specialized Agencies (Privileges and Immunities) Regulations (Cth) – reg 8(1).

Convention on the Privileges and Immunities of the Specialized Agencies [1988] ATS 41 – Sections 18-19, 22.