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Mussalli v Commissioner of Taxation [2020] FCA 544

April 27, 2020

TAXATION — Income tax — Deductibility — Payments made upon entering into lease and licence agreements of franchise restaurants — Payments described as prepayments of rent —Whether payments were capital in nature or on revenue account — Substance and form — Characterisation of advantage sought — Consideration of general principles — Income Tax Assessment Act 1997 (Cth) s 8-1 — Income Tax Assessment Act 1936 (Cth) s 82KZMD


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