Commissioner of Taxation v Consolidated Press Holdings Ltd

Commissioner of Taxation v Consolidated Press Holdings Ltd Commissioner of Taxation v Murray Leisure Group Pty Ltd CPH Property Pty Ltd v Commissioner of Taxation

Income Tax – Income Tax Assessment Act 1936 (Cth) Pt IVA - Income Tax Assessment Act 1936 (Cth) s 79D - Whether allowability of deduction for interest on borrowed funds a tax benefit - Whether allowability of deduction would, but for a scheme, have been defeated by s 79D - quarantining of interest deductions to foreign source income - Whether s 79D capable of application where no income was derived from a foreign source - Whether anticipated income from the transaction of which the borrowing was a part would have been income derived from a foreign source.

Income tax – Income Tax Assessment Act 1936 (Cth) Pt IVA - Dividend stripping - Corporate reorganisation - Relocation of holding structure from United Kingdom to Bahamas - Whether transfers of shares in United Kingdom companies a scheme by way of or in the nature of dividend stripping - Whether s 177E intended to apply only to schemes which can be said to have the dominant purpose of tax avoidance.

Words and phrases – "dividend stripping", "income from a foreign source".

Income Tax Assessment Act 1936 (Cth) – Pt IVA, ss 51, 79D, 160AFD, 177A, 177C, 177D, 177E, 177F.