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

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
Contributor
Subject
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
Instantiates
Publication
Label
Bywater Investments Ltd and others v Commissioner of Taxation; Hua Wang Bank Berhad v Commissioner of Taxation : [2015] FCAFC 176
Publication

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