Alesco New Zealand Ltd v Commissioner of Inland Revenue - [2012] 2 NZLR 252

Revenue — Tax avoidance — Issue by subsidiary to Australian parent of convertible notes — Deductions for notional interest — Whether arrangement constituted tax avoidance — Whether taxpayer took unacceptable tax position — Whether taxpayer took abusive tax position — Assessment counteracting impermissible deductions — Whether Commissioner obliged to assess on basis of next best alternative — Tax Administration Act 1994, ss 141B and 141D.