BHP Billiton Limited (BHP Group Ltd) v CofT – High Court upholds Commissioner’s CFC attribution assessment of the whole of Australian Dual Listed’ entity’s share of its Marketing Hub’s income – the UK Dual Listed’s subsidiary suppliers were ‘associates’ because they were ‘sufficiently influenced’
On Wed 11 March 2020, the High Court dismissed an appeal from a decision of the Full Court of the Federal Court of Australia – upholding CFC ‘attribution’ assessments on with whole of the Australian ‘dual listed’ entity’s share of the Marketing Hub ultimately owned by the Australian and UK dual listed entities. The High…