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Revenue versus capital: That old chestnut paper

Published on 18 Mar 15 by NATIONAL DIVISION, THE TAX INSTITUTE

This paper covers:

  • SPI PowerNet Pty Ltd v Commissioner of Taxation
  • Commissioner of Taxation v Citylink Melbourne Limited
  • Commissioner of Taxation v Star City Pty Limited
  • Cliffs International Inc v FCT
  • reconciling the cases
  • capitalised labour
  • why capital treatment isn’t (necessarily) the end of the world - an analysis of various Division 40 provisions
  • taxpayer alert on property developers.

Author profiles

Jayshil Prasad ATI
Jay Prasad is a Senior Associate in the tax group at Allens. Jay routinely advises on the income tax aspects of transactions and on tax disputes. He is particularly experienced in advising clients on large infrastructure projects and cross border investments. - Current at 18 June 2018
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Katrina Parkyn ATI
Photo of author, Katrina PARKYN Katrina is a Partner in the Tax group at King & Wood Mallesons. Based in Brisbane, she routinely advises on transactions Australia-wide across a broad spectrum of income tax, stamp duty and GST issues. Her experience includes advising on major infrastructure, resources and funds management. - Current at 26 June 2019
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This was presented at 30th National Convention .

Get a 20% discount when you buy all the items from this event.

Individual sessions









The Income Tax Assessment Acts: Statutes in senescence

Author(s):  AH (Tony) SLATER

Materials from this session:




The latest on the ATO’s management of tax audits and disputes

Author(s):  Damien BROWNE,  Ashley KING

Materials from this session:












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