Federal Court of Australia
FEDERAL COURT OF AUSTRALIA
Syngenta Crop Protection Pty Ltd (ACN 002 933 717) v Commissioner of Taxation [2005] FCA 1646
PRACTICE AND PROCEDURE – request by taxpayers for further particulars and discovery of documents in income tax 'appeal' – motion dismissed
INCOME TAX – issues on appeal in relation to transfer pricing provisions of Act and adjustment of business profits pursuant to double taxation treaty
Income Tax Assessment Act 1936 (Cth) ss136, 136AA, 136AD, 136AE, 175, 177
Taxation Administration Act 1953 (Cth) ss 14ZZ, 14ZZO, 14ZZP
Convention Between the Government of Australia and the Government of the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, Article 7
Commissioner of Taxation v Sleight (2004) 136 FCR 211 referred to
SYNGENTA CROP PROTECTION PTY LTD (ACN 002 933 717) v COMMISSIONER OF TAXATION
NSD 1039–1044 OF 2004
AMERICAN EXPRESS INTERNATIONAL INC (ABN 15 000 618 208) v COMMISSIONER OF TAXATION
NSD 308 OF 2005 GYLES J
9 NOVEMBER 2005
SYDNEY
IN THE FEDERAL COURT OF AUSTRALIA
NEW SOUTH WALES DISTRICT REGISTRY NSD 1039 OF 2004
BETWEEN: SYNGENTA CROP PROTECTION PTY LTD (ACN 002 933 717)
APPLICANT
AND: COMMISSIONER OF TAXATION
RESPONDENT
JUDGE: GYLES J
DATE OF ORDER: 9 NOVEMBER 2005
WHERE MADE: SYDNEY
THE COURT ORDERS THAT:
1. The motion be dismissed.
2. Costs of the motion will be the Commissioner's costs in the cause.
3. The matter be stood over to 9.30 am on Wednesday, 7 December 2005 with liberty to restore in the meantime on three days' notice.
Note: Settlement and entry of orders is dealt with in Order 36 of the Federal Court Rules.
IN THE FEDERAL COURT OF AUSTRALIA
NEW SOUTH WALES DISTRICT REGISTRY NSD 1040 OF 2004
BETWEEN: SYNGENTA CROP PROTECTION PTY LTD (ACN 002 933 717)
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