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CUB Australia Holding Pty Ltd v Commissioner of Taxation [2021] FCA 43

TAXATION – notice to give information – where Commissioner sought particulars of documents that were the subject of legal professional privilege claims – where the particulars sought comprised the titles of the documents, and the names of the authors and recipients of the documents – whether the notice was invalid on the ground that it was not authorised by the enactment, or that it was issued for an improper purpose, or that the Commissioner had taken into account an irrelevant consideration – where the taxpayer alleged that the Commissioner’s purpose in issuing the notice was to determine the validity of the taxpayer’s legal professional privilege claims – whether the taxpayer’s contention as to purpose was established.

Full decision here


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