ZENTRUM HOLDINGS LTD AND ANOR V COMMISSIONER OF INLAND REVENUE SC 44/2006

ZENTRUM HOLDINGS LTD AND ANOR V COMMISSIONER OF INLAND REVENUE SC 44/2006

Leave to appeal was granted on the discrete question whether the Farnsworth principle continues to apply and, if so, whether it precludes the Commissioner from arguing the transactions were a sham, because that issue was sufficiently arguable; leave was refused on the s108 ground because it was not sufficiently...

Source-derived case information.

Citation
SC 44/2006
Parties
Applicant: Zentrum Holdings Limited; Applicant: Ngahemi Properties Limited (as the Zentrum Holdings Group); Respondent: Commissioner of Inland Revenue
Court
Supreme Court
Jurisdiction
New Zealand
Judgment Date
19 September 2006
Procedural Posture
Appeal / Leave Granted (supreme Court)
Outcome
Leave to appeal granted on the Farnsworth/sham issue; leave refused on the s108 time‑bar point.
Legal Topics
Sham Doctrine, Tax Assessment Time Bar, Section 108 Tax Administration Act 1994, Farnsworth Principle, Leave to Appeal Under Supreme Court Act 2003
Tax Law Statutory Interpretation Civil Procedure Administrative Law Sham Doctrine Tax Assessment Time Bar Section 108 Tax Administration Act 1994 Farnsworth Principle +1 more

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Parties

Zentrum Holdings Limited

Applicant

Ngahemi Properties Limited (as the Zentrum Holdings Group)

Applicant

Commissioner of Inland Revenue

Respondent

Procedural Posture

Appeal / Leave Granted (supreme Court)

  1. 1 Whether the Farnsworth principle continues to apply under the tax legislation applicable to the issues in dispute
  2. 2 Whether the Farnsworth principle precludes the Commissioner from arguing on appeal that the applicants' transactions were a sham
  3. 3 Whether s108 of the Tax Administration Act 1994 bars the Commissioner from advancing the sham argument

Ratio Decidendi

Leave to appeal was granted on the discrete question whether the Farnsworth principle continues to apply and, if so, whether it precludes the Commissioner from arguing the transactions were a sham, because that issue was sufficiently arguable; leave was refused on the s108 ground because it was not sufficiently arguable that the Commissioner's position would increase the amount assessed so as to fall within the time bar in s108.

Court Disposition

Leave to appeal granted on the Farnsworth/sham issue; leave refused on the s108 time‑bar point.

Orders

  • Leave to appeal granted on the ground: Whether the principle in CIR v Farnsworth [1984] 1 NZLR 428 continues to apply under the tax legislation applicable to the issues in dispute and, if so, whether it precludes the Commissioner from arguing on appeal that the applicants' transactions were a sham.
  • Leave to appeal refused on proposed ground 1(d): whether s108 of the Tax Administration Act 1994 bars the Commissioner from advancing the argument that the transactions were a sham.