Catchwords
Taxation – Income tax – Allowable deductions – Charges were imposed on holder of electricity transmission licence pursuant to State regulatory framework – Taxpayer purchased assets of electricity transmission business including electricity transmission licence – Taxpayer required to pay charges to State of Victoria under asset sale agreement – Whether payments of charges were outgoings "of capital, or of a capital nature" and therefore not tax deductible.
Words and phrases – "capital", "capital account", "of a capital nature", "revenue account".
Electricity Industry Act 1993 (Vic) – ss 163A, 163AA.
Income Tax Assessment Act 1997 (Cth) – s 8-1(2)(a).