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On 11 March 2020, the High Court unanimously dismissed the taxpayer’s appeal from the Full Federal Court regarding attribution of income under Part X of the ITAA 1936.
Key to the decision was the High Court’s reasoning that each of BHP Billiton Ltd and BHP Billiton Plc exercised ‘sufficient influence’ over the other within the meaning of s 318(6) of the ITAA 1936.
An expert panel – including two counsel who appeared in the matter before the High Court – discuss the decision and key implications for taxpayers.
Commissioner of State Revenue v Placer Dome Inc  HCA 59 (5 December 2018) provides valuable insight into valuations in a mining context and a detailed discussion of legal and valuation issues related to goodwill. The decision is likely to be influential in many different tax contexts, including stamp duty, capital gains tax and tax consolidations. Eugene Wheelahan S.C. will explain the decision and explain some of its potential implications for tax law.