Commissioner of Inland Revenue v. Lin, [2018] NZCA 38 -- summary under Article 24

Chinese tax spared on Chinese CFC income and attributed under CFC regime to New Zealand shareholder was not “in respect of” income derived by that shareholder from China

As a result of having a 30% interest between 2005 and 2009 in four companies which were resident in China, the taxpayer had the active business...

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Words and Phrases
in respect of