15 Apr 2008
ANZ NATIONAL BANK LIMITED & ORS V THE COMMISSIONER OF INLAND REVENUE HC WN CIV 2005-485-1037
- Citation
- openlaw-4d07410f_02c6_4b74_8aea_0a0f70cb067b.pdf
- Court
- High Court
Accountants' tax advice documents from KPMG and PwC that are relevant to the objective assessment of the transactions (including documents explaining scope, steps, pricing, purpose, accounting treatment, cash flows, structuring and tax shelter management) are discoverable; a blanket class confidentiality/order protecting accountants' advice is inappropriate given statutory scheme (TAA and Evidence Act) and lack of evidential foundation; confidentiality claims must be particularised in accordance with the High Court Rules and will be considered after discovery; specific orders were made to dis…