Chatfield & Co Ltd v Commissioner of Inland Revenue - [2018] 2 NZLR 835

Judicial review — Justiciability — Commissioners’ power to obtain information — Commissioner’s decision to issue notices requiring information about 15 companies — Information sought by Korea under double tax agreement — Whether Commissioner acting lawfully in issuing notices — Whether information sought was “necessary” — Delegation — Intensity of review — Judge refusing to consider documents not disclosed as “matter of state” to applicant — Commissioner refusing to provide confidential supporting documents — Vienna Convention on the Law of Treaties.

Revenue — Practice and procedure — Commissioners’ power to obtain information — Review of decision to issue notices requiring information about 15 companies — Information sought by Korea under double tax agreement — Whether Commissioner acting lawfully — Whether information sought was “necessary” — Vienna Convention on the Law of Treaties.