The Resource Bywater Investments Ltd and others v Commissioner of Taxation; Hua Wang Bank Berhad v Commissioner of Taxation : [2015] FCAFC 176
Bywater Investments Ltd and others v Commissioner of Taxation; Hua Wang Bank Berhad v Commissioner of Taxation : [2015] FCAFC 176
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The item Bywater Investments Ltd and others v Commissioner of Taxation; Hua Wang Bank Berhad v Commissioner of Taxation : [2015] FCAFC 176 represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item Bywater Investments Ltd and others v Commissioner of Taxation; Hua Wang Bank Berhad v Commissioner of Taxation : [2015] FCAFC 176 represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- Summary
- Judgment by the Federal Court of Australia, judgment date 11 December 2015. The taxpayers were companies which admittedly carried on business in Australia but claimed not to be resident there for the purposes of the Income Tax Assesment Act 1936 and of various double taxation agreements to which Australia was a party. Three of the taxpayer companies contended that their place of central management and control was in the UK, Switzerland or Samoa. The Commissioner alleged that these companies were all controlled by a Mr Gould who resided in Sydney and that the directors acted on his instructions
- Language
- eng
- Label
- Bywater Investments Ltd and others v Commissioner of Taxation; Hua Wang Bank Berhad v Commissioner of Taxation : [2015] FCAFC 176
- Title
- Bywater Investments Ltd and others v Commissioner of Taxation; Hua Wang Bank Berhad v Commissioner of Taxation : [2015] FCAFC 176
- Language
- eng
- Summary
- Judgment by the Federal Court of Australia, judgment date 11 December 2015. The taxpayers were companies which admittedly carried on business in Australia but claimed not to be resident there for the purposes of the Income Tax Assesment Act 1936 and of various double taxation agreements to which Australia was a party. Three of the taxpayer companies contended that their place of central management and control was in the UK, Switzerland or Samoa. The Commissioner alleged that these companies were all controlled by a Mr Gould who resided in Sydney and that the directors acted on his instructions
- Citation source
- In: International tax law reports. - London. - Vol. 18 (2016), part 3 ; p. 343-362
- Language note
- English
- http://library.link/vocab/relatedWorkOrContributorName
- Baker, P
- http://library.link/vocab/subjectName
-
- case law
- tax treaty
- residence
- central management and control
- Label
- Bywater Investments Ltd and others v Commissioner of Taxation; Hua Wang Bank Berhad v Commissioner of Taxation : [2015] FCAFC 176
- Label
- Bywater Investments Ltd and others v Commissioner of Taxation; Hua Wang Bank Berhad v Commissioner of Taxation : [2015] FCAFC 176
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Bywater-Investments-Ltd-and-others-v-Commissioner/uOZE4CJCvjQ/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Bywater-Investments-Ltd-and-others-v-Commissioner/uOZE4CJCvjQ/">Bywater Investments Ltd and others v Commissioner of Taxation; Hua Wang Bank Berhad v Commissioner of Taxation : [2015] FCAFC 176</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="http://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
