Holding company's currency gain on sale not treated as asset transfer profit for tax purposes.

The Administrative Court allowed the tax authority's claim that currency gains realized by a holding company upon asset sale were not taxable as transfer profits. The court found that the Tax Act distinguishes between random selling profits and gains arising from asset transfers, prohibiting the offset of random selling losses against the former. Consequently, the tax authority was correct to exclude the currency gain from the calculation of the transfer profit for the 1991 tax year.