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Challenge Corporation Ltd v Commissioner of Inland Revenue - [1986] 2 NZLR 513

$30.00

High Court Wellington
3, 4 April; 8 August 1984
Barker J
Court of Appeal Wellington
1, 2 October; 19 December 1985
Woodhouse P, Cooke and Richardson JJ
Privy Council Wellington
21, 22 July; 20 October 1986
Lord Keith of Kinkel, Lord Brightman, Lord Templeman, Lord Oliver of Aylmerton and Lord Goff of Chieveley
Income tax — Tax avoidance — Overlap of anti-avoidance provisions — Group accounting — Purchase of company with accumulated loss — Intent of purchase was to off-set group's profits — Whether compliance with specific statutory provision negates compliance with general provision — Whether purchase of company was tax avoidance or tax mitigation — Income Tax Act 1976, ss 99 and 191 (as it stood prior to amendment in 1978).

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