Consideration of the relevant statutory provisions may, perhaps, tend to diminish the importance in this case of the general distinction between these two conceptions. Section 221C (1) is in the following terms: - "For the purpose of enabling the collection by instalments from employees of income tax, where an employee receives or is entitled to receive from an employer in respect of a week or part thereof salary or wages in excess of two pounds, the employer shall, at the time of paying the salary or wages, make a deduction therefrom at such rate as is prescribed." For the purposes of this section "employer" is defined to mean a person who pays or is liable to pay any salary or wages and "employee" means a person who receives, or is entitled to receive, salary or wages. "Salary or wages" is defined to mean "salary, wages, commission, bonuses or allowances paid (whether at piece-work rates or otherwise) to an employee as such" and includes, inter alia, any payments made "under a contract which is wholly or substantially for the labour of the person to whom the payments are made". Before the magistrate the competing submissions of the parties were, apparently, directed mainly to the latter provision but, for reasons which will presently appear, the respondent's liability does not necessarily turn upon it. It is clear that moneys paid to an independent contractor in satisfaction of a contractual obligation do not, in the ordinary legal sense, represent salary or wages. Nor are the general words of the definition of "salary or wages" appropriate to assimilate the remuneration of an independent contractor to the defined term. "Salary or wages" means salary, wages, commission, bonuses or allowances paid to an employee as such. The question then arises whether the particular provision that the defined term shall include payments made under a contract which is wholly or substantially for the labour of the person to whom the payments are made sufficiently widens the meaning of the term to embrace, at least in some circumstances, the remuneration of an independent contractor. In the argument addressed to this Court there may have been a suggestion that if in the case of any independent contractor it appeared that the parties contemplated that the contractual work would be substantially performed by the independent contractor himself, although the terms or conditions of the contract, whether express or implied, did not actually require it, the particular extension of the defined term would be sufficient justification for characterizing his remuneration as salary or wages for the purposes of s. 221C. This suggestion, however, is without validity, for if the contract leaves the contractor free to do the work himself or to employ other persons to carry it out the contractual remuneration when paid is not a payment made wholly or at all for the labour of the person to whom the payments are made. It is a payment made under a contract whereby the contractor has undertaken to produce a given result and it becomes payable when, and only when, the contractual conditions have been fulfilled. Moreover, the nature of the payment is not affected by the circumstance that the contractor has himself performed the bulk of the work under the contract or that it was the expectation of the parties that he would do so if, in truth, the contract did not create the relationship of master and servant. It may be, however, that in cases where an independent contractor is required by the terms of his contract to perform the contractual work himself the addition to the general definition may have some application, but it is unnecessary, in the circumstances of this case, to express any concluded view concerning contracts of such a special class. If this be so, however, it is the result rather of chance than design for the extension of the defined term was not, in our view, directed to considerations of the nature referred to. Its language is, in our opinion, designed to deal with circumstances of another kind. It is not unusual for contracts of employment to create obligations on the part of the servant not only to make his services or labour available to the master but also to do additional things. He may, for instance, be required to provide his own tools or equipment: (cf. Mutual Acceptance Co. Ltd. v. Federal Commissioner of Taxation [1] ). Or, on the other hand, the contract may provide for additional payments to be made to the employee based on circumstances which, in one sense, may be thought to be extraneous to the mere provision of his services such as a special living allowance in specified areas: (cf. The Tergeste [2] and Midland Railway Co. v. Sharpe [3] ). Probably the word "allowance" in the general definition would, at least in most cases, be sufficient to embrace payments of the latter kind (Mutual Acceptance Co. Ltd. v. Federal Commissioner of Taxation [1] ), but the reasons of the minority in that case may have afforded grounds for making some form of special provision for such cases. In many such cases the payments stipulated for may be said to be payments made under a contract wholly or substantially for the labour of the person to whom the payments are made, though it is a simple matter to conceive examples of the former class where remuneration might be said to be substantially for the hire of plant or equipment: see, e.g. Humberstone v. Northern Timber Mills [4] and Wright v. Attorney-General for the State of Tasmania [5] . In any such cases, however, the critical question will be one of fact, but no such question arises in the present case for if the tradesmen, in any of the instances under review, were free to carry out the contractual work themselves or to engage others to perform it for them, either in whole or in part, the payments received by any particular tradesman were in no sense made under a contract for his labour.