Vinelight Nominees et al v CIR

I successfully appeared for the Commissioner in this litigation. This is the first case concerning the residence of a company since the 1995 case of New Zealand Forest Product Finance Ltd NV v C of IR [1995] 2 NZLR 353. It is also the first High Court case to consider the application of s NF 5 of the ITA. Finally it involves issues concerning the application of the time bar to RWT returns, tax avoidance and the application of shortfall tax penalties for taking an abusive tax position.


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