Search - 2002年 抽纸品牌 质量排名

HMRC, [2016] UKSC 21-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) firm paying for PwC accounting services was not entitled to a credit for the VAT because PwC was not contractually obligated to it In 2002, the appellant (“Airtours”), which was in financial difficulty, instigated the preparation of a report by an accounting firm (“PwC”) to satisfy around 80 lenders (the “Institutions”) that its proposed restructuring and refinancing proposals were viable. ... Ss. 26(1) and (2) provided that the amount of allowable input tax is that which is “attributable to” taxable “supplies … made or to be made by the taxable person in the course or furtherance of his business.” ...

Singapore Telecom Australia Investments Pty Ltd v Commissioner of Taxation, [2024] FCAFC 29-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 an independent enterprise would have agreed to allow interest to be capitalized, but not to make it contingent on cash flow The taxpayer (“STAI”)- a wholly-owned Australian subsidiary of a Singapore public company (Singapore Telecommunications Limited, or “SingTel”)- purchased in June 2002 all the shares of an Australian telecommunications company (“SOPL”) from another wholly-owned subsidiary of SingTel (“SAI”), which was accepted to be a Singapore enterprise. ... It rejected the contention of STAI that the amount of interest actually paid over the 10 year period was equal to or less than that which might be expected to have been paid between independent parties in similar circumstances over the same period, as the transfer-pricing standard was required to be met on a tax year by tax year basis – and the Commissioner had the discretion to adjust the interest for earlier years upwards. ...

Singapore Telecom Australia Investments Pty Ltd v Commissioner of Taxation, [2024] FCAFC 29-- summary under Subsection 247(2) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2) arm’s length interest could be capitalized but not made contingent on cash flow of borrower, and should reflect a parent guarantee without a guarantee fee The taxpayer (“STAI”)- a wholly-owned Australian subsidiary of a Singapore public company- purchased in June 2002 all the shares of an Australian telecommunications company from a Singapore sister company (“SAI”). ... It rejected the contention of STAI that the amount of interest actually paid over the 10 year period was equal to or less than that which might be expected to have been paid between independent parties in similar circumstances over the same period, as the transfer-pricing standard was required to be met on a tax year by tax year basis – and the Commissioner had the discretion to adjust the interest for earlier years upwards. ...

However, in a September 5, 2018 proposal letter, the Minister proposed to assess Milgram for its 1998 to 2002 taxation years (the “earlier years”) based on an estimate of Milgram’s investment income for those years, stating that this assessment came about due to “misrepresentation” attributable to “neglect, carelessness or wilful default.” ... Go J then stated (at paras. 114-115): According to the SCC [in Dow Chemical], if this Court decides to quash a decision on administrative law grounds, and the Minister issues a new decision that affects the amount of taxes owing, the assessment will be incorrect if it does not accurately reflect the new opinion. … [The 2021] notices of objection have not been adjudicated. ...

Commissioner of Taxation, [2015] FCAFC 154, aff'd [2016] HCA 42-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) phantom profit participation unit amounts not income until paid by employer rather than when due The taxpayer was employed by Glencore International AG (“GI”) or a subsidiary from November 1991 to December 2006, with his employment in Australia commencing in 2002 when he also became an Australian resident. ... There was therefore no derivation of income in the 2007 income year when the first two instalments, though due, were merely withheld from payment to the appellant. … The applicant derived the first two instalments as income when, in January 2008, they were paid, with his agreement, to the FTA by GI on his behalf. ...