Minerva Financial Group Pty Ltd v Commissioner of Taxation [2022] FCA 1092

TAXATION – Income Tax Assessment Act 1936 (Cth) Part IVA – where applicant taxpayer appealed under s 14ZZ of the Taxation Administration Act 1953 (Cth) from an objection decision made by the Commissioner of Taxation against amended assessments – where applicant did not dispute that it had entered into or carried out a “scheme” within the meaning of s 177A of the Income Tax Assessment Act 1936 (Cth) – where applicant did not dispute that it had obtained a tax benefit within the meaning of s 177C of the Income Tax Assessment Act 1936 (Cth) – where three schemes alleged by the Commissioner of Taxation – whether a reasonable person would conclude that applicant entered into or carried out one or more of the schemes for the dominant purpose of enabling it to obtain a tax benefit in connection with the scheme within the meaning of s 177D of the Income Tax Assessment Act 1936 (Cth)

Full decision here