The promotion and management of a sport, even a healthy sport such as soccer, is not a charitable or benevolent purpose for the purposes of the payroll tax exemption under s 48(1)(c) of the Payroll Tax Act 2007 (NSW). Non-profit sporting organisations cannot claim payroll tax exemption on the basis that their sport promotes health and community wellbeing. The dominant purpose of an organisation must be determined by reference to both its constitutional objects and its activities, not its objects alone.
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