Chief Commissioner of State Revenue v Print National Pty Ltd

(2013) 83 NSWLR 555; [2013] NSWCA 96

NSW Court of Appeal

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Interrogate

Catchwords

1. Taxes and Duties
2. › Payroll Tax
3. › Administration
4. › Objections and reviews
5. › Right to object to decisions of Chief Commissioner
6. › Whether 'dissatisfied' in s 86(1)(b) limited to decisions having immediate and direct effect on tax liability
7. › Taxation Administration Act 1996 (NSW), ss 72, 86(1)(b), 96(1), 103A
1. Statutory Interpretation
2. › Ordinary meaning
3. › Whether statutory term bears ordinary or special meaning
4. › Whether context requires departure from ordinary meaning
5. › Taxation Administration Act 1996 (NSW), s 86(1)(b)
1. Administrative Law
2. › Judicial review and merits review
3. › Scope of reviewable decisions
4. › Whether investigative decisions amenable to objection and review
5. › Taxation Administration Act 1996 (NSW), ss 86(1)(b), 96, 97, 103A
6. › Administrative Decisions Tribunal Act 1997 (NSW), s 6

Quick Take

The word 'dissatisfied' in s 86(1)(b) of the Taxation Administration Act 1996 (NSW) bears its ordinary meaning of 'displeased' and is not limited to decisions having an immediate and direct effect on a taxpayer's actual or potential tax liability. Decisions of the Chief Commissioner to issue investigative notices under s 72 are amenable to objection under s 86(1)(b) and review by the ADT under s 96(1) or the Supreme Court under s 97.