*Re Crown Insurance Services Ltd and FCT – Commissioner appeals (like a dog that won’t give up its bone) the AAT decision that the Vanuatu insurance company was neither resident, nor had any Australian source income [C8]

The Commissioner has appealed to the Federal Court against the decision in AAT Case [2011] AATA 847, Re Crown Insurance Services Ltd and FCT. The AAT had held that an insurance company (the taxpayer) incorporated in Vanuatu neither carried on a business in Australia nor had its central management and control in Australia, and therefore, was not an Australian resident during the relevant years. It also held the taxpayer’s income in the years in question was not derived from sources in Australia.

[LTN 1, 4/1]