Sunraysia Harvesting Contractors Pty Ltd (Trustee) v Commissioner of Taxation [2017] FCA 694

20Jun2017

TAXATION – income tax – assessable income – amended assessments – goods and services tax – taxable supplies and creditable acquisitions – transactions claimed by Commissioner to be “sham” – whether corporate taxpayer entered into a sham arrangement in respect of labour hire –whether interposed subcontracting companies genuine and real – arrangements never intended to create legally enforceable obligation – companies not making supply for consideration or carrying on enterprise – no allowable deduction for payments by corporate taxpayer to purported subcontractors - no onus on Commissioner to prove that arrangement a sham – whether taxpayers discharged onus of proving that arrangement was not a sham – failure to show assessments excessive – objection decisions affirmed. Click here