A liquidator's remuneration on a time-cost basis should be assessed by reference to whether the time was reasonably expended, not whether the work added financial value to creditors. The 'broad brush approach' to remuneration assessment is not appropriate where the evidence permits specific assessment of objections. Categories of non-remunerable work include ultra vires work, negligent work, unnecessary work, work by persons of inappropriate seniority, and work at inappropriate hourly rates. Costs of negotiating and securing third-party funding arrangements are ordinarily reflected in hourly rates and are not separately remunerable.
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