Commissioner of Taxation v BHP Billiton Limited – BHP entities held to be ‘associates’ of Billiton (UK) entities, under their ‘dual-listed’ structure – for CFC purposes

On 29.1.19, the Full Federal Court allowed the Commissioner’s appeal and found that BHP on the issue of whether it’s ‘dual-listed’ arrangements, with the UK Billiton company, made BHP subsidiaries, ‘associates’ of the Billiton entities, for Controlled Foreign Corporations (CFC) purposes. At issue was whether BHP had to return (under the CFC provisions) its share…

University ‘Tax Clinics’ – Labor would fund Melbourne Uni’s clinic, allow them to register as tax agents and to get DGR status

On 15.4.19, Shadow Assistant Treasurer: Mr Andrew Leigh announced that a Labor government would provide the University of Melbourne’s ‘Tax Clinic’ $150,000 annually as part their policy to have 10 tax clinics around Australia, facilitate their registration as a tax agent and also give them Deductible Gift Recipient status. See below for the entire media…

Glencore’s case in the High Court, seeking orders that the ATO return and not use ‘privileged’ documents stolen the Paradise Papers leak – decision reserved after hearing

On 17.4.19, the High Court heard the case brought by Glencore International seeking orders that the ATO deliver up documents it had obtained, relating to Glencore, following the 2017 leak of the so called ‘Paradise Papers’ (see related Tax Technical article). They also sought an injunction restraining the ATO from using those documents. The High…