CIR v BNZ Investments Ltd
| Jurisdiction | New Zealand |
| Date | 2002 |
| Court | Court of Appeal |
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20 cases
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Peterson v Inland Revenue Commissioner (New Zealand)
...and there is nothing for the Commissioner to counteract. As Richardson P said in Commissioner of Inland Revenue v BNZ Investments Ltd [2002] 1 NZLR 450 at p 464: "… it is inherent in the section that, but for its provisions, the impugned arrangements would meet all the specific requirements......
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Comptroller of Income Tax v AQQ
...or two or more connected but distinct 'arrangements' (as there were in Commissioner of Inland Revenue v BNZ Investments Ltd[2002] 1 NZLR 450) is a question of fact for the [Commissioner]. ... 44 The Comptroller had chosen - before the Board, the High Court and indeed before us - to particul......
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Lodge Real Estate Ltd v Commerce Commission
...the definition of “arrangement” in what is now s YA 1 of the Income Tax Act 2007: Commissioner of Inland Revenue v BNZ Investments Ltd [2002] 1 NZLR 450 (CA) at [45]–[46] per Richardson P, Keith and Tipping JJ. We see that formulation as having the same shortcoming as “moral 52 See above at......
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Comptroller of Income Tax v AQQ and another appeal
...or two or more connected but distinct "arrangements" (as there were in Commissioner of Inland Revenue v BNZ Investments Ltd [2002] 1 NZLR 450) is a question of fact for the [Commissioner]. … The Comptroller had chosen – before the Board, the High Court and indeed before us – to particularis......
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1 books & journal articles
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General Anti-Avoidance Rules and Tax Treaties: A South African Perspective
...accessed on 7 October 2020.143Olivier & Honiball, (Siber Ink 2011) 511.144See CIR v BNZ Investments (2002) 1 NZLR 450 regarding general anti-avoidanceprovisions (GAAP), where the court held: ‘By contrast with specific anti-avoidance provisionswhich are directed to particular defined situa......