Commissioner of Taxation v Healius Ltd [2020] FCAFC 173

Appeal from: Healius Ltd v Commissioner of Taxation [2019] FCA 2011

TAXATION – appeals from decision dismissing appellant’s applications to appeal from objection decisions by Commissioner of Taxation – where lump sum amounts paid to medical practitioners under arrangements to conduct practice from respondent’s medical centres – whether primary judge erred in finding lump sum amounts made on revenue account for income tax purposes – whether primary judge erred by adopting narrow conception of nature of business – whether lump sum amounts paid to secure arrangements that formed part of profit-making structure of business – whether accounting treatment of lump sum amounts as goodwill supports claim that lump sum amounts made on capital account – consideration of distinction between capital and revenue expenditure – appeals allowed

Full decision here