This presentation covers:
Six primary taxpayers (between them across some 12 decisions) have sought the Court’s guidance on how to correctly interpret section 100A.
While the intention of this presentation is to give you a summary of the learnings that each Court decision provides, we have also sought to distil a set of ten guiding principles to use as a starting point for section 100A analysis to help shape your analysis.
These principles (commandments if you will) are by no means exhaustive. But they are, at least to the authors’ minds, ten common themes that arise from the Courts’ interpretation and application of this section over the past 45 years, and are designed to help you answer the question – section 100A yea or nay?