Part IVA decision on stapled structure arrangement

The Federal Court has handed down the most noteworthy decision on Part IVA for a number of years and it raises a number of interesting technical, evidential and strategic issues along with potentially broader implications.

The Federal Court handed down its decision in Minerva Financial Group Pty Ltd v Commissioner of Taxation [2022] FCA 1092 on 16 September 2022. It is the most noteworthy decision on Part IVA of the Income Tax Assessment Act 1936 for a number of years and it raises a number of interesting technical, evidential and strategic issues along with potentially broader implications. The taxpayer’s structure in this case shares similar features to the stapled structure arrangements which have been an ...

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Authors: Keith Swan, Alice Chow

Published Date: 05 October 2022