Commissioner of Taxation v Crown Insurance Services Ltd

• 1. Administrative Law
  2. › Appeal from Administrative Appeals Tribunal
  3. › Appeal on question of law
  4. › Whether finding that income not derived from Australian source raises question of law
  5. › Distinction between question of law, mixed question of law and fact, and question of fact
  6. › Whether facts necessarily fall within statutory provision or reasonably admit of different conclusions
  7. › Administrative Appeals Tribunal Act 1975 (Cth), s 44
• 1. Taxation
  2. › Income tax
  3. › Assessable income of foreign resident
  4. › Income derived directly or indirectly from Australian sources
  5. › Source of premium income of foreign insurer
  6. › Whether premium income of Vanuatu insurer derived indirectly from Australian sources
  7. › Income Tax Assessment Act 1997 (Cth), s 6-5(3)(a)

Quick Take