Queensland Judgments
Authorised Reports & Unreported Judgments
  • sclq logo
  1. Caselaw
  2. QCATA
  3. 2023
  4. Sorensen v Commissioner of State Revenue - [2023] QCATA 49

Authorised Reports & Unreported Judgments
Exit Distraction Free Reading Mode
  • Unreported Judgment

Sorensen v Commissioner of State Revenue[2023] QCATA 49

Sorensen v Commissioner of State Revenue[2023] QCATA 49

QUEENSLAND CIVIL AND ADMINISTRATIVE TRIBUNAL

CITATION:

Sorensen & ors v Commissioner of State Revenue [2023] QCATA 49

PARTIES:

brent sorensen

ante rados

cameron david walsh

(applicant/appellant)

v

commissioner of state revenue

(respondent)

APPLICATION NO/S:

APL039-20; APL040-20; APL041-20

ORIGINATING APPLICATION NO/S:

GAR342-18; GAR343-18; GAR344-18

MATTER TYPE:

Appeals

DELIVERED ON:

30 March 2023

HEARING DATE:

20 July 2022

HEARD AT:

Brisbane

DECISION OF:

Senior Member Traves

ORDERS:

  1. The appeal is dismissed.
  2. The parties must file in the Tribunal two (2) copies and exchange one (1) copy of submissions, if any, on the costs of the appeal by 4:00pm on 20 April 2023.
  3. The question of costs of the appeal will be determined on the papers, after 20 April 2023.

CATCHWORDS:

APPEALS – TAXES AND DUTIES – STAMP DUTIES – EXEMPTIONS – CONVEYANCE OR TRANSFER ON SALE OF REAL PROPERTY – QUEENSLAND – where transfer from home unit company to individual upon surrender of shares granting right of occupancy – where exemption requires Lot to “have been used for residential purposes” immediately prior to transfer – whether Member erred in law in construing whether Lots “had been used for residential purposes”

Duties Act 2001 (Qld), s 133

Queensland Civil and Administrative Tribunal Act 2009 (Qld), s 142, s 146, s 147

APN Outdoor (Trading) Pty Ltd v Melbourne City Council [2012] VSC 8

Chief Commissioner of State Revenue v Metricon Qld Pty Ltd (2017) 105 ATR 11

Gladstone Town Council v Gladstone Harbour Board (1964) 11 LGRA 231

Educang Limited v Brisbane City Council [2002] QSC 374

Minister Administering the Crown Lands Act v NSW Aboriginal Land Council (1993) 31 NSWLR 106

Newcastle City Council v Royal Newcastle Hospital (1957) 96 CLR 493

Newcastle City Council v Royal Newcastle Hospital (1959) 100 CLR 1

Pearson v Thuringowa City Council [2006] 1 Qd R 416

Perpetual Corporate Trust Limited v Commissioner of State Taxation [2022] SASC 7

APPEARANCES & REPRESENTATION:

 

Applicant:

HL Alexander, counsel instructed by LGA Lawyers

Respondent:

S. Amos, counsel, instructed by the Commissioner of State Revenue

REASONS FOR DECISION

  1. [1]
    This is an appeal of a decision by the Tribunal confirming the decision of the Commissioner of State Revenue on objection that the community titles exemption from transfer duty, did not apply.[1] The relevant transaction was the transfer of five lots in a new townhouse development from the company which built the townhouse complex (97 Holberton Street Pty Ltd) to each of the transferees. Lots 1 and 2 were transferred to Mr Sorensen; lot 3 to Mr Walsh; and Lots 4 and 5 to Mr Rados.
  2. [2]
    The relevant exemption is contained in s 133 of the Duties Act 2001 (Qld) (Duties Act).
  3. [3]
    The appeal grounds have been amended since the application for leave to appeal or appeal was filed on 14 February 2020.[2] The appeal grounds were further amended at the commencement of the hearing of the appeal when the appellants, by their counsel, discontinued their application for leave to appeal on all grounds bar the first ground, which is as follows:

The Member erred in law in construing subsection 133(1)(e) of the Duties Act 2001 (Qld), that the Member adopted the wrong legal test at paragraphs [39] and [44] of the QCAT decision of 14 January 2020, and that on its proper construction of the statutory provision encompassed:

(a) the passive use of the vacant townhouses where they were wholly devoted to occupation for residential tenancies; or

(b) further or alternatively, an actual use of the vacant townhouses for residential purposes after completion and certification even if such use was not itself occupation as a home or residence.

  1. [4]
    Notwithstanding the parties agree the appeal turns on the proper statutory construction of the phrase “has been used for residential purposes in s 133(1)(e) of the Duties Act 2001 (Qld)”,[3] the appeal ground raises three issues:
    1. (a)
      whether the Member erred in construing subsection 133(1)(e) of the Act;
    2. (b)
      whether the Member adopted the wrong legal test at [39] and [44]; and
    3. (c)
      that the statutory provision encompasses the matters in (a) and (b) of the appeal ground.
  2. [5]
    The first two issues are questions of law, for which no leave is required.[4] The third issue assumes facts which are not established in the judgment; and which are not the subject of appeal.
  3. [6]
    In deciding an appeal on a question of law only, the Appeal Tribunal may make the orders set out in s 146 of the Queensland Civil and Administrative Tribunal Act 2009 (Qld) (QCAT Act). Section 146 provides:

146Deciding appeal on question of law only

In deciding an appeal against a decision on a question of law only, the appeal tribunal may –

  1. (a)
    confirm or amend the decision; or
  2. (b)
    set aside the decision and substitute its own decision; or
  3. (c)
    set aside the decision and return the matter to the tribunal or other entity who made the decision for reconsideration –
  1. (i)
    with or without the hearing of additional evidence as directed by the appeal tribunal; and
  2. (ii)
    with the other directions the appeal tribunal considers appropriate; or
  1. (d)
    make any other order it considers appropriate, whether or not in combination with an order made under paragraph (a), (b) or (c).
  1. [7]
    The Appeal Tribunal may only substitute its own decision if the error of law disposes of the proceeding entirely or it may do so based on the findings of fact made by the decision-maker whose decision is appealed.[5]
  2. [8]
    The Queensland Court of Appeal held in Ericson v Queensland Building and Construction Commission[6] that the Appeal Tribunal has no power under s 146 to conduct a re-hearing so as to reach its own conclusions on the evidence.[7] If I find that resolution of the legal question could not determine the outcome of the matter I must return the matter to the Tribunal Member.

Background

  1. [9]
    The development the subject of the appeal is a group of 5 units, referred to as Townhouses by the appellants. The Townhouses were originally owned by 97 Holberton Street Pty Ltd (the company).
  2. [10]
    The company was incorporated on 19 July 2013 for the sole purpose of purchasing land and undertaking a development at 97 Holberton Street.[8] The company organised for a builder to build the Townhouses.
  3. [11]
    Each of the three appellants held redeemable preference shares which entitled each appellant a right to:
    1. (i)
      use and occupy their respective Townhouse/s upon completion of the building works for the Townhouses; and
    2. (ii)
      request a transfer of their respective Townhouse/s to each appellant.
  4. [12]
    ‘Practical completion’ was reached sometime between April and June 2016.
  5. [13]
    On 21 June 2016 each of the appellants entered into a residential licence agreement with the company: each licence being for a unit corresponding to the lot that would result from subdivision. Each agreement was stated to give the relevant applicant a licence to occupy the unit for ‘personal accommodation’ until the unit was acquired by the licensee or, if there was no transfer, during two periods up to 16 October 2017.
  6. [14]
    On 13 July 2016 the land was subdivided into five lots and common property as a community titles scheme.
  7. [15]
    On 19 July 2016 the appellants and the company entered into five separate contracts for the transfer of each of the five lots in the property. In respect of each contract, the consideration given by each of the appellants was the surrender of the redeemable preference shares, relating to the particular lot, that he held in the company.
  8. [16]
    The ‘separate area that the lot comprises’ referred to in s 133(1)(d) and (e) are:
    1. (a)
      Unit 1, 97 Holberton Street, Newtown, Queensland – transferred to the first appellant (Lot 1);
    2. (b)
      Unit 2, 97 Holberton Street, Newtown, Queensland – transferred to the first appellant (Lot 2);
    3. (c)
      Unit 3, 97 Holberton Street, Newtown, Queensland – transferred to the third appellant (Lot 3);
    4. (d)
      Unit 4, 97 Holberton Street, Newtown, Queensland – transferred to the second appellant (Lot 4);
    5. (e)
      Unit 5, 97 Holberton Street, Newtown, Queensland – transferred to the second appellant (Lot 5).
  9. [17]
    The Member found that the date the shares were transferred should be assumed to be the date of settlement of the contracts, being 19 August 2016.
  10. [18]
    The day the contracts were entered into, that is, on 19 July 2016, the five transfers were executed. The transfers were registered on 1 September 2016. On that day, each of the appellants became the registered proprietors of their respective Lot/s.
  11. [19]
    The Lots were each rented out to tenants. The leases started on various dates between 26 September 2016 and 1 December 2016.

The legislation

  1. [20]
    The Duties Act is taxing legislation. Chapter 2 concerns transfer duty. By s 8, transfer duty is imposed on dutiable transactions, including the transfer of dutiable property. Part 13 of Chapter 2, in which s 133 appears, relates to exemptions for transfer duty. Division 4 of Part 13 specifically relates to exemptions for dealings under particular Acts.
  2. [21]
    Section 133(1) of the Duties Act provides:

133EXEMPTION—COMMUNITY TITLES SCHEMES

  1. (1)
    Subject to subsection (2), transfer duty is not imposed on a transfer, or agreement for the transfer, of a lot that, under the Body Corporate and Community Management Act 1997, is a lot included in a community titles scheme if—
  1. (a)
    the transferor is a corporation (the "transferor corporation"); and
  2. (b)
    under that Act, the transferor corporation is the original owner for the scheme; and
  3. (c)
    the transferee held shares in the transferor corporation that were surrendered to obtain the transfer of the lot from the transferor corporation; and
  4. (d)
    the separate area that the lot comprises corresponds with the separate area the transferee had a right to occupy immediately before surrendering the transferee’s shares; and
  5. (e)
    the separate area that the lot comprises has been used for residential purposes immediately before the transferee surrendered the transferee’s shares and will, after registration of the plan and the transfer of the lot to the transferee, be used for residential purposes.
  1. (2)
    Subsection (1) applies to the transfer or agreement for the transfer of a lot by a transferor corporation on or after the commencement day only if—
  1. (a)
    before the commencement day—
  1. (i)
    shares were issued by the transferor corporation; and
  2. (ii)
    the corporation’s constitution provided, and on and from the commencement day continues to provide, that a person who holds the shares has the right to occupy the separate area mentioned in subsection (1) (d) ; or
  1. (b)
    before the commencement day, the transferee entered into an agreement with the transferor corporation under which—
  1. (i)
    the transferee is entitled to purchase the shares mentioned in subsection (1) (c) from the transferor corporation; and
  2. (ii)
    because of the purchase of the shares, the transferee has the right to occupy the separate area mentioned in subsection (1) (d).
  1. (3)
    In this section—

"commencement day" means the day this section commences.

  1. [22]
    It was not disputed below or on appeal that all the criteria for exemption, save the condition that the lot had been used for residential purposes immediately before the transfer, were satisfied.

The decision below

  1. [23]
    Relevantly, the learned Member held that s 133(1)(e) of the Duties Act was not satisfied on the basis that the separate area that each lot comprised was not used for residential purposes immediately before the surrender of the relevant shares.
  2. [24]
    The Member referred to the submissions of the applicants that a lot can be used for residential purposes without being physically occupied. Further that ‘used’ and ‘residential purposes’ should not be narrowly interpreted; that ‘use’ is broader than ‘occupy’ and that ‘residential purposes’ connotes that the purpose of a lot is residential rather than, for example, commercial or industrial. The Member then referred to the submissions of the Commissioner that actual use or physical occupation of a lot is required to satisfy the term ‘has been used’ in s 133(1)(e). Further, that s 133(1)(e) is directed to continuity of residential use.
  3. [25]
    The learned Member held:
    1. (a)
      A place might be properly described, in some circumstances, as being used for residential purposes even if unoccupied.[9]
    2. (b)
      The Member gave the following examples of where an apartment might be seen to be used for residential purposes notwithstanding it was unoccupied:
      1. Where a property that is tenanted is vacant for a period between tenants. There, the Member said, there is an expectation of ongoing residential use, as distinct from, say, industrial use. The residential purpose has not been abandoned.[10]
      2. Where a person builds an apartment with the intention of renting it out. There, the Member said, the person might fairly be described as using the apartment for residential purposes even before a tenant moves in, while the owner is searching for a tenant or, for example, while the owner is furnishing the apartment to attract potential tenants.[11] 
  4. [26]
    The Member distinguished the situation before him,[12] finding that notwithstanding the impression sought to be created by the constitution of the company and licence agreements and the connection of electricity, that, when viewed as a whole, none of the applicants ever intended to rent out or personally occupy as a home their townhouses before the transfer from the company to individual ownership.[13] The Member found that renting them out earlier would have added complexities to both the leasing arrangements and the income tax arrangements. The understanding, reflected in the Recitals to the Shareholder Agreement, was that these steps would promptly follow the completion of construction.[14] Accordingly, that the applicants did not use the townhouses for residential purposes, but more accurately, for holding purposes.[15]

Appellants’ submissions

  1. [27]
    The appellants submit that for the purposes of s 133(1)(e), a lot can be used for residential purposes without being occupied. It is argued that the Member applied the wrong legal test in the following respects:
    1. (a)
      The words “used for” in the phrase “has been used for residential purposes” imported an element of futurity into the use of the proposed lots by the shareholders;
    2. (b)
      It is sufficient if it be shown that the proposed lot had been wholly devoted to residential purposes and the fulfilment of that purpose does not require the immediate physical use or occupation of the proposed lot as residential premises at the specified time;
    3. (c)
      Further, or alternatively, if there is a sufficiently proximate and not too remote connection between the proposed lot in a physical sense and what is done in or in the course of devoting it to residential purposes, that is sufficient to demonstrate ‘use’ of the proposed lot for residential purposes;
    4. (d)
      The issue of the final inspection certificate/certificate of classification was sufficient to show that an intended future use for residential accommodation had sufficiently come to fruition to be a present use of proposed lot for residential purposes;
    5. (e)
      Further or alternatively, the concept of ‘use’ requires only so much physical activity as is necessary to fulfil the purpose being served, whether that be recurrent activity, infrequent activity, isolated activity, or no activity at all.
  2. [28]
    The appellants contend the Tribunal erred in adopting and applying a legal test that is substantially based on whether the Townhouses had been physically ‘occupied’ as residential premises, including temporary vacancies shortly before or after letting while searching for tenants, not whether they had been ‘used’ for residential purposes in accordance with the foregoing tests.
  3. [29]
    The appellants also contend that when the question is the purpose for which land or a building has been used on a given day, it calls for an inquiry, not limited to the physical activities on the land or building on that day, but taking account of any course of user, or other user, which may fairly be regarded as current on that day. The question is what are the acts, facts, matters and circumstances which are said to show that the land has been used for residential purposes, and the function of the Tribunal is to undertake that evaluation.
  4. [30]
    Finally, the appellants contend that if the Tribunal had used the correct construction of “has been used for residential purposes” in s 133(1)(e) of the Duties Act, that would have meant a decision wholly in favour of the appellants or that would have made a material difference as it would have resulted in a different consideration of the importance or relevance of the primary materials and resulted in different findings of fact and ultimate conclusions of fact, in which case the matter should be remitted to the Tribunal for further consideration according to law.

Respondent’s submissions

  1. [31]
    The Commissioner submits that the proper construction of s 133(1)(e) of the Duties Act requires the actual use or physical occupation of a lot for it to be ‘used for residential purposes’.

Consideration

  1. [32]
    The starting point is the text of the provision, read in its context and with regard to the statutory purpose. Ultimately, the question turns upon the particular wording in this Act.
  2. [33]
    The critical words are “the separate area that the lot comprises has been used for residential purposes immediately before the transferee surrendered the transferee’s shares”. Had the area been used for residential purposes immediately before the surrender?
  3. [34]
    The words “been used” immediately before the surrender require that the use had already taken place by the time of the surrender.
  4. [35]
    The appellants contend the Tribunal erred in adopting and applying a legal test that is substantially based on whether the Townhouses had been physically “occupied” as residential premises, including temporary vacancies shortly before or after letting while searching for tenants, not whether they had been ‘used’ for residential purposes in accordance with the tests they purported to identify and which I have set out in paragraph [28].
  5. [36]
    The appellants’ proposition that the Tribunal adopted a ‘test’ “substantially based” on physical occupation acknowledges, as was the fact, that the Member’s reasoning went beyond the absence of physical occupation. The Member acknowledged that a place might be described as being used for residential purposes notwithstanding it was unoccupied. The Member’s reasoning included consideration of a number of matters which, taken together, led to a conclusion that the premises had not, at the relevant time, “been used for residential purposes”. The Member found, in effect, the premises had been constructed for the purpose of use for residential purposes, but had not by the time of the transfer “been used” for residential purposes. That the Member’s reasoning included the facts that the appellants did not occupy, nor did they ever intend to occupy or rent the premises for occupation for residential purposes before the transfer is unremarkable: both were and were treated by the Member as part of the indicia that by the time of the transfer the premises had not “been used” for residential purposes.
  6. [37]
    This process of reasoning did not, in my view, involve error. The nature and extent of physical occupation necessary to demonstrate that the premises are in fact being so used will depend, amongst other things, on the nature of the use.[16] And, when determining whether a use has occurred, it is reasonable to direct attention to the ordinary indicia of that use.[17] In the Member’s view, the matters relied upon by the appellants as amounting to use of the residential premises for residential purposes did not establish the use. In my view there was no error in the Member’s reasoning or his conclusion.
  7. [38]
    Accordingly, in my view, the Member did not err in the manner described by the appellants.
  8. [39]
    The appellants submit that the words “used for” in the phrase “has been used for residential purposes” imported an element of futurity into the use of the proposed lots by the shareholders. In my opinion, that is incorrect. The words “has been” used for must be given effect. They are plainly expressed in the past tense. Moreover, that use must be one that exists immediately before the transferee surrendered the transferee’s shares. So, rather than importing an element of futurity, the relevant words direct attention to a use at a particular point of time in the past.
  9. [40]
    The appellants submit that it is sufficient if it be shown that the proposed lot had been wholly devoted to residential purposes and the fulfilment of that purpose does not require the immediate physical use or occupation of the proposed lot as residential premises at the specified time. I respectfully disagree.
  10. [41]
    The words “wholly devoted to residential purposes” are not words of precise application. They might be fulfilled, for example, by the physical occupation for living by a family. What really is contended here is that the construction of the premises for future residential use, together with the certificate of classification and grant of the licence (and some other evidence, such as connection of the electricity), is sufficient for a finding that the premises “have been used” for residential purposes at the time of the transfer. It is of some note that s 133 in its terms distinguishes between “a right to occupy immediately before surrendering the transferee’s shares” and the use of the area for residential purposes at the same moment in time, that is, immediately before the surrender of the transferee’s shares. This necessarily suggests that a right to occupy for residential purposes (s 133(1)(d)) is not of itself sufficient to satisfy the requirement that the area has been used for residential purposes, immediately before the surrender, under s 133(1)(e).
  11. [42]
    The appellants’ submission, in my view, gives no or inadequate effect to the words “had been used” by conflating the existence of the use with the purpose of the use.
  12. [43]
    The appellants submit, further or alternatively, that if there is a sufficiently proximate and not too remote connection between the proposed lot in a physical sense and what is done in or in the course of devoting it to residential purposes, that is sufficient to demonstrate ‘use’ of the proposed lot for residential purposes. That may be so. Ultimately the “proximity” of the connection, if sufficiently close, may give rise to the relevant “use”. But the question remains whether, on these facts, the premises “had been used”.
  13. [44]
    It was submitted that the issue of the final inspection certificate/certificate of classification was sufficient to show that an intended future use for residential accommodation had sufficiently come to fruition to be a present use of proposed lot for residential purposes. The Member dealt with a like submission at first instance at [32].[18] I respectfully agree with the Member’s reasoning. At best, the certificate is part of the factual evidence relevant to what is, ultimately, a factual determination. To suggest that the certificate was “sufficient” is, with respect, incorrect and ignores the rest of the evidence.
  14. [45]
    Finally, the appellants submit that the concept of ‘use’ requires only so much physical activity as is necessary to fulfil the purpose being served, whether that be recurrent activity, infrequent activity, isolated activity, or no activity at all. But the relevant phrase is not “use”, but “had been used”. And it is not a matter of “fulfilling” a purpose”, but a use “for” a purpose at a particular point in time. It does not involve the fulfilment, over a continuum of time, of a “purpose being served”. While in the most general sense the inquiry demanded by the relevant words is one of fact and degree, I do not accept the gloss which the appellants’ submissions place upon the section.

Conclusion

  1. [46]
    For the reasons above, in my view, the learned Member did not err in the manner contended by the appellants.
  2. [47]
    Having found no error, I do not remit the matter to the Tribunal Member.
  3. [48]
    The appeal is dismissed.
  4. [49]
    I direct that the parties make submissions, if any, on the costs of the appeal by 4:00pm on 20 April 2023. The question of costs will be determined on the papers, without an oral hearing, after 20 April 2023.

Footnotes

[1] Sorensen & ors v Commissioner of State Revenue [2020] QCAT 7.

[2] Tribunal Order dated 6 April 2022.

[3] Appellants’ Joint Appeal Submissions filed on 11 November 2020 at [3], [7], [11]; Respondent’s Appeal Reply Submissions filed on 9 December 2020 at [11].

[4] Queensland Civil and Administrative Tribunal Act 2009 (Qld), s 142(1) and s 142(3)(b); Cutbush v Scenic Rim Regional Council (No 2) [2019] QCATA 167 at [7].

[5] Clarke v Body Corporate for Tuner Park Shopping Village CTS [2019] QCATA 51 at [11].

[6] [2014] QCA 297.

[7] Ibid at [13].

[8] 97 Holberton Pty Ltd Shareholders Agreement dated 10 October 2013.

[9] Sorensen & ors v Commissioner of State Revenue [2020] QCAT 7 at [39].

[10] Ibid.

[11] Ibid.

[12] Ibid at [40].

[13] Ibid at [41]-[44].

[14] Ibid at [43].

[15] Ibid at [44].

[16] Minister Administering the Crown Lands Act v NSW Aboriginal Land Council (1993) 31 NSWLR 106.

[17] Pearson v Thuringowa City Council [2006] 1 QdR 416.

[18] Sorensen & ors v Commissioner of State Revenue [2020] QCAT 7.

Close

Editorial Notes

  • Published Case Name:

    Sorensen & Ors v Commissioner of State Revenue

  • Shortened Case Name:

    Sorensen v Commissioner of State Revenue

  • MNC:

    [2023] QCATA 49

  • Court:

    QCATA

  • Judge(s):

    Senior Member Traves

  • Date:

    30 Mar 2023

Appeal Status

Please note, appeal data is presently unavailable for this judgment. This judgment may have been the subject of an appeal.

Cases Cited

Case NameFull CitationFrequency
APN Outdoor (Trading) Pty Ltd v Melbourne City Council [2012] VSC 8
1 citation
Jump To
Cite 1 - [2012] VSC 8
Chief Commissioner of State Revenue v Metricon Qld Pty Ltd (2017) 105 ATR 11
1 citation
Jump To
Cite 1 - (2017) 105 ATR 11
City of Newcastle v Royal Newcastle Hospital (1959) 100 CLR 1
1 citation
Jump To
Cite 1 - (1959) 100 CLR 1
Clarke v Body Corporate for Turner Park Shopping Village [2019] QCATA 51
1 citation
Jump To
Cite 1 - [2019] QCATA 51
Cutbush v Scenic Rim Regional Council (No. 2) [2019] QCATA 167
1 citation
Jump To
Cite 1 - [2019] QCATA 167
Educang Limited v Brisbane City Council [2002] QSC 374
1 citation
Jump To
Cite 1 - [2002] QSC 374
Ericson v Queensland Building and Construction Commission [2014] QCA 297
2 citations
Jump To
Cite 1 - [2014] QCA 297
Cite 2 - [2014] QCA 297
Gladstone Town Council v Gladstone Harbour Board (1964) 11 LGRA 231
1 citation
Jump To
Cite 1 - (1964) 11 LGRA 231
Minister Administering the Crown Lands Act v NSW Aboriginal Land Council (1993) 31 NSWLR 106
2 citations
Jump To
Cite 1 - (1993) 31 NSWLR 106
Cite 2 - (1993) 31 NSWLR 106
Newcastle City Council v Royal Newcastle Hospital (1957) 96 CLR 493
1 citation
Jump To
Cite 1 - (1957) 96 CLR 493
Pearson v Thuringowa City Council[2006] 1 Qd R 416; [2005] QCA 310
2 citations
Jump To
Cite 1 - [2006] 1 Qd R 416
Cite 2 - [2006] 1 Qd R 416
Perpetual Corporate Trust Limited v Commissioner of State Taxation [2022] SASC 7
1 citation
Jump To
Cite 1 - [2022] SASC 7
Sorensen v Commissioner of State Revenue [2020] QCAT 7
7 citations
Jump To
Cite 1 - [2020] QCAT 7
Cite 2 - [2020] QCAT 7
Cite 3 - [2020] QCAT 7
Cite 4 - [2020] QCAT 7
Cite 5 - [2020] QCAT 7
Cite 6 - [2020] QCAT 7
Cite 7 - [2020] QCAT 7

Cases Citing

No judgments on Queensland Judgments cite this judgment.

1

Require Technical Assistance?

Message sent!

Thanks for reaching out! Someone from our team will get back to you soon.

Message not sent!

Something went wrong. Please try again.