Freelance Global Ltd v Chief Commissioner of State Revenue

[2014] NSWSC 127

Supreme Court of NSW

Built by Barristers,
For Australian Law.

1. TAXATION — Payroll tax — Employment agency contracts — Whether taxpayer procured the services of contractors for clients — Contracts and arrangements between taxpayer, contractors and clients — Whether contracts were employment agency contracts — Relevance of pre-contractual discussions and arrangements between contractors and clients — Whether "relevant contracts" provisions engaged — Whether request for refund required Chief Commissioner to make a reassessment — Payroll Tax Act 1971 ss 3A, 3AA, 3C, 6, 7, 8 — Payroll Tax Act 2007 ss 6, 7, 31-36, 37-40 — Taxation Administration Act 1996 ss 9, 14, 17