In calculating profits on an account of profits against errant fiduciaries, the salaries of those fiduciaries who actually worked in the business must be treated as a business expense (reducing the profits), even where the fiduciaries acted dishonestly. The denial of an equitable 'allowance' for work and skill on grounds of dishonesty is a different concept from the treatment of remuneration as an ordinary business expense necessary to earn the profits. Interest on borrowings used to finance the wrongful acquisition is also an allowable expense. Section 1317H(2) of the Corporations Act 2001 (Cth) is definitional — it brings profits into the compensatory scheme even absent corresponding loss, but does not change the method of calculating those profits.
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