Federal Court of Australia
FEDERAL COURT OF AUSTRALIA
Financial Synergy Holdings Pty Ltd v Commissioner of Taxation [2016] FCAFC 31 Appeal from: Financial Synergy Holdings Pty Ltd v Commissioner of Taxation [2015] FCA 53
File number: VID 88 of 2015
Judges: MIDDLETON, LOGAN AND DAVIES JJ
Date of judgment: 10 March 2016
Catchwords: TAXATION – capital gains tax – where consolidated group formed – disposal of pre-CGT assets – calculation of cost base of pre-CGT assets – meaning of "worked out as at the time of the acquisition" – s 110-25(2) of Income Tax Assessment Act 1997 – effect of deeming provision s 122-70(3) of Income Tax Assessment Act 1997
Legislation: Income Tax Assessment Act 1997 (Cth) Divs 109, 110, Subdivs 109-B, 110-A, 122-A, 126-B, ss 102-20, 104-5, 104-10, 109-5, 109-50, 109-55, 110-25(2), 122-15, 122-20, 122-40, 122-70, 701-1, 701-10, 705-10, 705-60, 705-65, 716-855, 950-100, 950-150, 995(1)
Cases cited: Commissioner of Taxation v Comber (1986) 10 FCR 88 Cooper Brookes (Wollongong) Pty Ltd v Commissioner of Taxation (1981) 147 CLR 297
Date of hearing: 25 August 2015
Registry: Victoria
Division: General
National Practice Area: Taxation
Category: Catchwords
Number of paragraphs: 49
Counsel for the Appellant: B Sullivan SC with C Burnett
Solicitor for the Appellant: PricewaterhouseCoopers
Counsel for the Respondent: S Steward QC with E Wheelahan
Solicitor for the Respondent: Australian Taxation Office, Review and Dispute Resolution
ORDERS VID 88 of 2015
BETWEEN: FINANCIAL SYNERGY HOLDINGS PTY LTD Appellant
AND: COMMISSIONER OF TAXATION Respondent
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