4 Apr 2016
PRACTICAL CIVIL SERVICES LIMTED v COMMISSIONER OF INLAND REVENUE [2016] NZHC 593 [4 April 2016]
- Citation
- [2016] NZHC 593
- Court
- High Court
The alleged late-2010 agreement was process-based and required the taxpayer to provide elections and prescribed information; the company unreasonably delayed and failed to provide valid elections by the deadline in the Commissioner's 19 May 2014 letter, which validly made time of the essence; the Commissioner lawfully cancelled the arrangement and called up the 2010 assessment in January 2015; therefore there is no fairly arguable substantial dispute under s290(4)(a) and the statutory demand could not be set aside.