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Abstract

In February 1991, the Federal Commissioner of Taxation (inexplicably withdrew his appeal against the decision of Davies J in Metropolitan Oil Distributers (Sydney) Pty Ltd v FCT (1990). This paper examines whether the arrangements entered into by the taxpayer could have been struck down by the Commissioner had they been entered into after 27 May 1981. In doing so, it provides a useful analysis of the effectiveness of the Part IVA provisions.

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