Insights

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Recent Victorian tax announcements – what do you need to know?

The Victorian government recently announced a number of key state tax changes. The State Taxation Acts Amendment Bill 2023 (Bill) has passed the Legislative Assembly and has been read for a second...

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Constitutional challenge to validity of state charge on e-vehicles

The High Court of Australia is currently considering whether Victorian legislation imposing a fee on the use of zero or low-emission vehicles is contrary to s 90 of the Commonwealth Constitution in...

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Guardian: the Full Federal Court confirms Part IVA applies on round two of trust distributions

The Commissioner of Taxation (Commissioner) has been actively pursuing the application of the anti-avoidance provisions to trust structures and trust distributions. In the most recent decision, the...

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Deductions for depreciating assets – no guarantee that the reasoning in Shell Energy applies

The ATO has issued its decision impact statement (DIS) about a year after the Full Federal Court decision in Shell Energy Holdings Australia v Commissioner of Taxation [2022] FCAFC 2 (Shell Energy).

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Taxpayer win in Full Federal Court Appeal against Commissioner on GST Margin Scheme

On 22 December 2022, the Full Federal Court of Australia unanimously decided for the taxpayer in Commissioner of Taxation v Landcom. The decision is a useful reminder of key principles in statutory...

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Court finds arrangements that include a trustee's income distribution decisions are Part IVA schemes

A single judge of the Federal Court has upheld a decision of the Commissioner of Taxation (Commissioner) to apply the general anti-avoidance rule, Part IVA, to arrangements that include the income...

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ATO Decision Impact Statement regarding Aurizon: clear objective evidence is important

On 25 August 2022, the Commissioner issued his decision impact statement in relation to Aurizon Holdings Limited v Commissioner of Taxation [2022] FCA 368 (Aurizon).

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State and Territory budgets snap shot – key business announcements

With the ACT releasing its budget on 2 August 2022, every Australian state and territory has now handed down its budget for the 2022/23 financial year. We outline below some of the key business...

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Regulators get tough on claims of Legal Professional Privilege

Following a number of recent cases in which parties have incorrectly claimed legal professional privilege (LPP) over documents to be produced for regulatory proceedings or investigations, and...

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Updated ATO approach to accessing records and information

On 22 June 2022, the Australian Taxation Office (ATO) published its finalised Protocol for claiming legal professional privilege (the Protocol). The Protocol has been developed to assist taxpayers...

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Changes to Duty Laws in NSW: options, anti-avoidance rules and promoter penalties now in force

On 19 May 2022, the State Revenue and Fines Legislation Amendment (Miscellaneous) Act 2022 (NSW) received royal assent (the Amending Act). The Amending Act made a number of amendments to the Duties...

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The ATO ramps up its recovery of existing and anticipated tax debts

Central to the Australian taxation system is the concept of self-assessment. Voluntary compliance for the payment of tax related liabilities is strong with Australian Tax Office (ATO) data...

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LPP “Smorgasbord” wars: Commissioner not entitled to all taxpayer’s documents

Moshinsky J handed down (in part) the highly anticipated decision: Commissioner of Taxation v Pricewaterhouse Coopers [2022] FCA 278, finding that only a portion of the respondent’s documents over...

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Corporate Collective Investment Vehicles - new regime now live

The Corporate Collective Investment Vehicle Framework and Other Measures Bill 2021 (Cth) (CCIV Bill) received Royal Assent on 22 February 2022. The CCIV Bill sets out the regulatory and tax...

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Tax litigation to watch in 2022

The Australian Taxation Office’s (ATO) stated approach to tax disputes is to seek to prevent them where appropriate.

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Commissioner of Taxation’s access powers

The Commissioner of Taxation has broad powers to obtain information and documents for the purposes of his administration of Australia’s tax laws.

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Federal Court agrees that deductions should be denied for interest on financing

On 17 December 2021, the Federal Court of Australia published the decision of Justice Moshinsky in Singapore Telecom Australia Investments Pty Ltd v Commissioner of Taxation [2021] FCA 1597.

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Victoria’s newest property tax - Windfall Gains Tax

In May this year, the Victorian government announced it would be introducing a Windfall Gains Tax (WGT) in order to tax the value of gains made by landowners as a result of certain rezoning...

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State and Territory budget snap shot – key business announcements

Following last year’s federal and state government budget deferrals, 2021 has seen a return to a more “normal” timetable for the states and territories releasing their budgets, with most...

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High Court refuses taxpayer special leave to appeal R&D case

On 2 September 2021, the High Court of Australia refused Coal of Queensland Pty Ltd (COQ) leave to appeal the decision of the Full Federal Court in Coal of Queensland Pty Ltd v Innovation and...

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Treasury consults on Corporate Collective Investment Vehicles

On 27 August 2021, the Department of the Treasury of the Australian Government (Treasury) released a package of documents including exposure draft legislation and exposure draft explanatory...

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Federal Budget 2021

In this special Insight we bring you the key taxation measures announced by the Treasurer, the Hon. Josh Frydenberg, in the 2021-22 Australian Federal Budget on Tuesday 11 May 2021.

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Taxpayer wins in latest AAT R&D decision

The Administrative Appeals Tribunal (AAT) recently held in favour of taxpayer PKWK in a research and development (R&D) dispute against Innovation and Science Australia (ISA).

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Federal Court dismisses H2O Exchange’s appeal from AAT R&D decision

On 22 January 2021, Stewart J decided H20 Exchange Pty Ltd (H2O) v Innovation and Science Australia (ISA) [2021] FCA 11 in favour of ISA.

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