Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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Actuarial deficit contributions to an approved superannuation fund are characterised by their purpose. Contributions made to bridge actuarially determined deficits, including prior-year deficiencies, are ad hoc gap-filling payments rather than ordinary annual contributions subject to the Rule 87 ceiling or initial contributions. Recurrence of deficits does not alter that character. Applying the ceiling to contributions necessary to meet actuarial liabilities could impair the fund's solvency and conflict with the deduction scheme for approved superannuation funds. On that basis, disallowance of the actuarial deficit contributions was deleted and the revenue's appeal failed.
Actuarial deficit contributions to an approved superannuation fund are characterised by their purpose. Contributions made to bridge actuarially determined deficits, including prior-year deficiencies, are ad hoc gap-filling payments rather than ordinary annual contributions subject to the Rule 87 ceiling or initial contributions. Recurrence of deficits does not alter that character. Applying the ceiling to contributions necessary to meet actuarial liabilities could impair the fund's solvency and conflict with the deduction scheme for approved superannuation funds. On that basis, disallowance of the actuarial deficit contributions was deleted and the revenue's appeal failed.
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