Ch’elle Properties (NZ) Ltd v Commissioner of Inland Revenue - [2004] 3 NZLR 274

Revenue — General anti-avoidance rule — Goods and services tax — Transaction exploiting differences in timing for payment basis and invoice basis — 114 houses each purchased by separate company, then on-sold to taxpayer — Settlement deferred ten years or more and input tax claimed by taxpayer — Whether general anti-avoidance rule applicable — Whether subjective intent to defeat intent and application of Act required — Goods and Services Tax Act 1985, s 76.