Description: The Arrangement is the AA Smartfuel Programme (the Programme). This is a rewards scheme where customers obtain entitlements to buy fuel at a discounted price from certain fuel providers by purchasing goods or services from certain retailers (Participating Reward Providers (PRPs)). The fuel providers may also be PRPs in respect of both fuel and non-fuel purchases.

Description: The Arrangement is the establishment and operation of the Fonterra Shareholders' Fund (FSF), a New Zealand resident unit trust through which non milk-supplying investors (Public Investors) and farmers supplying milk to Fonterra (Supplying Shareholders) are able to invest in units. Units in the FSF give Public Investors and Supplying Shareholders economic rights in Fonterra shares (Shares), but do not provide them with any legal interest in the Shares.

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Description: The disputant sought an order requiring the Commissioner of Inland Revenue ('the Commissioner') to issue a disclosure notice and statement of position with respect to its Notices of Proposed Adjustment ('NOPAs') that were part of a dispute progressing through the disputes process.

Description: The Michael Hill group of companies entered into a transaction in which it transferred its intellectual property and franchising operations within the group from New Zealand to Australia, using an Australian Limited Partnership ('ALP') as part of the finance structure.

Description: This case was about whether the disputant was liable to pay PAYE on monthly payments made to Mr X. The disputant argued that Mr X was a shareholder of the disputant and therefore the disputant was not required to return the PAYE owing as the monthly payments were not PAYE income payments to Mr X.