Zentrum Holdings Limited and Ngahemi Properties Limited v The Commmisioner of Inland Revenue - SC 44/2006
Summary
Civil – tax administration – in Taxation Review Authority (“TRA”) CIR argued unsuccessfully that Zentrum had benefited by a tax avoidance arrangement – on appeal to High Court CIR sought to argue that relevant transactions were shams – whether jurisdictional bar to raising sham argument for first time in High Court – whether it would have been open to CIR to employ sham argument in TRA – whether CIR v VH Farnsworth Ltd [1984] 1 NZLR 428 applies – whether sham argument is subject to time bar in Tax Administration Act 1994, s 108CA 215/05 23 May 2006
Result
Application for leave to appeal granted.
19 September 2006
_________________________
Notice of abandonment being lodged, the appeal is deemed to be dismissed.
4 April 2007
Additional Information
ZENTRUM HOLDINGS LTD AND ANOR v COMMISSIONER OF INLAND REVENUE SC 44/2006 [19 September 2006]
Commissioner of Inland Revenue v Zentrum Holdings Ltd [2006] NZCA 99 23 May 2006