Cross examination: contentious tax issues: Premium on goodwill; Three bites of the cherry; Goodwill ups and downs

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Published on 01 Jul 96 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE

A recent judicial decision at odds with the Commissioner's position in a contentious taxation ruling has led to the ruling's withdrawal, pending the finalisation of draft guidelines. The new draft ruling is relevant to any taxpayer who proposes to sell a business carried on in leased premises. This contentious issue is discussed in this article

Author profile

Prof Richard Vann CTA

Prof Richard Vann, CTA, is Challis Professor of Law at the University of Sydney and a Consultant at Greenwoods & Herbert Smith Freehills. He has also taught at NYU Law School, Harvard Law School and the University of London. He has held many government consultancies in Australia, including the Review of Business Taxation (1998•1999), the Review of International Taxation (2002•2003) and the Australian Taxation Office Public Rulings Panels on international and indirect taxation (1995•2007). Most recently, he has been involved in various Board of Taxation work on managed investment trusts and collective investment vehicles, the attribution of profits to permanent establishments and as a member of Treasury’s BEPS Advisory Group. Richard is the Editor-in-Chief of the IBFD Global Tax Treaties Commentaries now being progressively published online. - Current at 12 January 2017

More by Richard J VANN

Tax treaty developments paper - 09-October-2014
BEPS: The future of Australian and international taxation or the end of the corporate income tax? paper - 05-August-2014
BEPS: OECD perspective paper - 19-February-2014
Tax base erosion - What is likely to be the Australian legislative response going forward? paper - 23-October-2013
Tax base erosion - Emerging and likely developments paper - 18-September-2013
Treaty benefits and taxation of partners in limited partnerships holding shares in mining companies - 10-July-2013
Hill on tax treaties and interpretation - 01-June-2013
Practical implications of Australia’s recent tax treaties paper - 19-May-2011
Never-ending tax reform and financial services - 01-April-2011
Never ending tax reform and financial services paper - 10-February-2011
OECD 2010 paper - 22-September-2010
Bamford in the High Court: Short and sweet - 01-May-2010
Practical issues arising from Bamford paper - 17-September-2009
Property investment and tax treaties paper - 12-September-2007
Origins of concepts and expressions used in the OECD Model and their adoption by States. - 01-November-2006
Current tax treaty issues related to interpretation paper - 27-October-2005
Tax case: Losses lost due to lack of control - 01-July-2005
Tax Case: Our mutual friend gives clubs and cooperatives a dickens of a hiding - 01-April-2004
Australia's New Treaty Policy: Noise or music? seminar paper - 22-July-2003
Australia's Policy on Entity Taxation - 01-February-2001
Australia's policy on entity taxation - 01-January-2001
Entity taxation policy and design features - 09-November-2000
Foreign investment rules - 28-April-2000
Report of Australia's business tax review and the government's response - 04-October-1999
Internationalisation of Imputation - 30-July-1999
Case study: Rulings need a refit - 01-October-1998
Case study: Stretcher case - 01-September-1998
The new definition of dividend - 06-August-1998
Case study: Exhausts - 01-August-1998
Case study: CGT's new measure - 01-July-1998
Case study: Fare go - 01-June-1998
Case study: Come back, 108!: all is forgiven - 01-May-1998
Loss of prestige - 01-May-1998
Case studies: Depreciation - 01-April-1998
Case study: Musician's records were off-key - 01-April-1998
Agenda for tax reform - 01-November-1997
Case study: ATO given out on nil; Batteries jolt for gross-ups ruling - 01-September-1997
Taxation treaties - in the shadow of Thiel - 08-July-1997
Case study: Retro grade - 01-May-1997
Cross examination: Income diversion; the Result in Radilo - 01-March-1997
Cross examination: Through a Spotless glass, darkly - 01-February-1997
Cross examination: Public entities ownership - 01-February-1997
Cross examination: Through a Spotless glass, darkly - 01-February-1997
Five FBT frictions. 1. The childcare exemption; 2. Discount dining out; 3. Recent case law - 01-December-1996
Cross examination: Section 26AAC Escape Route? ; A Question of Collis ; The meaning of employee - 01-November-1996
Cross examination: Debt defeasance: the ICI Australia Case ; Burrill's case at face value ; Fallout from energy case - 01-September-1996
Cross examination: forfeit deposits: guys and dollars; Compensation payments; Frequent flyer tax grounded - 01-August-1996
Cross examination : premium on goodwill| Premium on goodwill - 01-July-1996
Developments in international tax law seminar paper - 14-June-1996
Cross examination : taken on trust; transfer of losses; CGT and loan guarantees - 01-June-1996
Cross examination : frank account of debt dividends - 01-May-1996
Cross examination - 01-April-1996
Cross examination : contentious tax issues - 01-March-1996
Cross examination : Sun sets on Sunrise - 01-February-1996
Cross examination : Spotless and sunset sets on sunruse - 01-February-1996
Cross examination : guidance draft ducks issues - 01-December-1995
Cross examination : next move in FCT v Rowe - 01-December-1995
Cross examination : warranty case warrants care - 01-December-1995
Tax Law Improvement : are we on the right track ? - 13-September-1995
Tax treaties in the 1990s - 24-August-1995
IMPROVING TAX LAW IMPROVEMENT: AN INTERNATIONAL PERSPECTIVE - 01-January-1995
The Fletcher's and World Book cases - 01-August-1992
The self-assessment amendments - 01-July-1992
The New Zealand imputation system: a comparison with Australia - 01-June-1989
The background and policy of the Australian international accruals regime - 01-January-1989
International developments in tax reform. Have we seen the end of major tax reforms in Australia or do reforms in other countries suggest that further measures are likely to be introduced here? - 01-December-1988
How Business Tax Planning Operates: Arbitrage, Imputation and International Investment - 01-January-1988
International developments in tax reform - 01-January-1988
A examination of the imputation system in the context of the erosion of the company tax base - 01-January-1987
The foreign tax credit and reform of international taxation - 01-January-1986
The boundaries of the capital gains tax - 01-January-1986
International implications of imputation - 01-January-1985

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