If that were not enough, then a careful examination of the In section 81c(a) The Ordinance shows that a significant part of the terms used by the section have been defined in other sections, sometimes in a way that is no less complex and branched than the way in which the term excess profits was defined. Just to illustrate, the term "Accumulated Profits Debtorsea" that appears at the beginning of Section 81C(a) defined as the difference between "Accrued Profits" and "Exempt earned earnings". "Accrued Profits" Defined In section 77(a) to the Ordinance (a full-paragraph long definition that includes references to other sections as well as sub-definitions), but to the Sections 81A-81F It is required to deduct from this sum the "The amount of accumulated profits attributed to the income of a shareholder of a minority company under this Ordinance, including under sections 3(i1), 62A, 64 or 64A". This sum may, as stated, reduce the company's exempt accumulated profits, and I will not bore the reader with the complex and branching definition of this term, which also appears In section 81A to the command. Indeed, complexity are the provisions that define them"Excess Profits", as is customary and apparently inevitable in tax legislation; However, there is no need for us to delve into the depths of the arrangement in this matter, for we are not dealing with the interpretation of the law, but with its constitutionality.
To this must be added, and this matter is essential to one of the petitioners' arguments, that In section 81b(b) Three cases have been established in which the minority company will not be required to pay the tax on excess profits:
(1) The amount of the losses of the minority company in the tax year in accordance with sections 28, 29 or 92 exceeds 10% of the amount of the profits accumulated by the minority company at the end of the previous tax year;
(2) The amount of dividends paid tax due to their distribution, which the minority company distributed to its shareholders, exceeds 50% of the amount of the surplus profits of the minority company at the end of the previous tax year;