TIB - October 1997

Legislation and determinations

• Determination S7: Morgan Stanley OPALS – Financial Arrangement Income or Expenditure from Morgan Stanley OPALS
• Transfer pricing – draft guidelines (see appendix for actual guidelines)

Questions we’ve been asked

• Income Tax Act 1994: Tax sparing – Fijian tax credits
• Goods and Services Tax Act 1985
  • GST and advertising purchased from a non-resident publisher
  • Collection of rents by an agent from domestic households

Legal decisions - case notes

• Section 25 time limitation on assessments: Hutchison Brothers Ltd v CIR
• Judicial Review – whether Disputes Tribunal can hear tax cases: CIR v Disputes Tribunal and JD Platt
• Leasing by builder – activity other than making taxable supplies?: CIR v JD Morris
• Motel vacant when transferred – sale of a going concern?: DC Belton v CIR