Penny v Commissioner of Inland Revenue - [2009] 3 NZLR 523

Income tax — Tax avoidance — Incorporated surgery practice — Lower than market salary paid by the company to surgeon — Whether company and trust trading structure plus lower than market salary “tax avoidance arrangement” — Whether assignment of income — Whether Personal Services Attribution Rules applied — Income Tax Act 1994, ss BG 1, GB 1(1), OB 1 and GC 14B.