Lochtenberg v Commissioner of Taxation [2019] FCA 1167

TAXATION – income tax – appeal on a question of law from decision of the Administrative Appeals Tribunal – taxpayer participated in employee incentive profit participation plan – taxpayer worked in Australia then Switzerland – amount payable after termination of employment – whether income exempt as foreign earnings derived from foreign service – whether facts fully found admitted of only one conclusion – whether Tribunal asked itself wrong question or applied wrong statutory test

Full decision here