JENNINGS ROADFREIGHT LIMITED (IN LIQUIDATION) v COMMISSIONER OF INLAND REVENUE [2014] NZSC 2

JENNINGS ROADFREIGHT LIMITED (IN LIQUIDATION) v COMMISSIONER OF INLAND REVENUE [2014] NZSC 2

The Supreme Court granted leave to appeal to resolve the substantive legal question whether the s 167(1) statutory trust survives the liquidation of a company or is extinguished so that the funds are governed by Schedule 7 of the Companies Act 1993.

Source-derived case information.

Citation
[2014] NZSC 2
Parties
First Applicant: Jennings Roadfreight Limited (in liquidation); Second Applicant: Boris van Delden and Roy Horrocks as liquidators of Jennings Roadfreight Limited (in liquidation); Respondent: Commissioner of Inland Revenue
Court
Supreme Court
Jurisdiction
New Zealand
Judgment Date
14 February 2014
Procedural Posture
Supreme Court Appeal / Leave to Appeal Granted
Outcome
Leave to appeal granted
Legal Topics
Statutory Trust Under S 167(1) Tax Administration Act 1994, Liquidation, Schedule 7 Companies Act 1993, Priority of Creditors, Continuance or Extinguishment of Statutory Trusts, Leave to Appeal
Tax Law Company Law Trust Law Insolvency Law Statutory Trust Under S 167(1) Tax Administration Act 1994 Liquidation Schedule 7 Companies Act 1993 Priority of Creditors +2 more

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Parties

Jennings Roadfreight Limited (in liquidation)

First Applicant

Boris van Delden and Roy Horrocks as liquidators of Jennings Roadfreight Limited (in liquidation)

Second Applicant

Commissioner of Inland Revenue

Respondent

Procedural Posture

Supreme Court Appeal / Leave to Appeal Granted

  1. 1 Whether the trust arising under s 167(1) of the Tax Administration Act 1994 continues in existence upon the liquidation of a company in respect of funds held in the company's account
  2. 2 Whether the trust is extinguished upon liquidation so that the funds are dealt with in accordance with Schedule 7 of the Companies Act 1993

Ratio Decidendi

The Supreme Court granted leave to appeal to resolve the substantive legal question whether the s 167(1) statutory trust survives the liquidation of a company or is extinguished so that the funds are governed by Schedule 7 of the Companies Act 1993.

Court Disposition

Leave to appeal granted

Orders

  • Leave to appeal is granted.
  • Approved ground for appeal: whether the trust arising under s 167(1) of the Tax Administration Act 1994 continues in existence upon the liquidation of a company, in respect of funds held in the company's account, or is extinguished upon the liquidation so that the funds held are dealt with in accordance with...