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The aggregation of transactions paper

Published on 25 Jul 13 by NATIONAL DIVISION, THE TAX INSTITUTE

Harry Lakis will outline the courts’ analysis of aggregation by reference to the key cases, with Jim Richards providing an administrator’s perspective. These papers will provide a comparison of the aggregation provisions and the Revenue Offices’ approaches, including:

  • how the “transfer model” jurisdictions differ from the others
  • factors required to be considered
  • when evaluating the factors, whose perspective is most relevant?
  • the availability of discretions
  • direction in which case law is moving
  • the approach taken when evaluating the aggregation of interests that may comprise a “significant interest” in the landholder/land rich context.

Author profile:

James Richards CTA
Jim is a Deputy Commissioner of Territory Revenue and Director of Revenue Collections within the Northern Territory Revenue Office. Jim is responsible for administering the Territory's payroll tax, stamp duty and home incentive schemes, including associated compliance functions. Jim has held a number of operational, compliance and policy positions within the Office at management level, and is a representative on a number of inter-Revenue Office working groups. Current at 10 May 2013 Click here to expand/collapse more articles by Jim RICHARDS.
 

This was presented at 13th Annual States' Taxation Conference.

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