Trustpower Ltd v Commissioner of Inland Revenue - [2014] 2 NZLR 502

Resource management — Resource consents — Consents sought as part of feasibility study for major infrastructure projects — Whether resource consents part of “development pipeline” or stand-alone assets — Resource Management Act 1991, ss 9, 10, 11, 12, 13, 14, 15 and 122.

Revenue — Income tax — Capital/revenue distinction — Expenditure to obtain resource consents — Overall purpose of expenditure — Whether stand-alone capital assets separate from projects to which related (“identifiable assets” test) — Whether expenditure within general permission because part of of feasibility expenditure or subject to capital limitation — “Development pipeline” — Resource Management Act 1991, ss 9, 12, 13, 14, 15, 88, 122(1) and 134 and sch 4, cl 9.