Commissioner of Taxation v Fortunatow [2020] FCAFC 139
Appeal from: Fortunatow v Commissioner of Taxation [2019] FCA 1247
TAXATION – personal services income provisions in the Income Tax Assessment Act 1997 (Cth) – personal services business tests – unrelated clients test – relationship between ss 87-20(1)(b) and 87-20(2) – proper construction of s 87-20(1)(b) – meaning of “as a direct result” – whether appeal competent – appeal allowed with costs
Full decision here