10 September 2014

Tax: ASB Bank v. Inland Revenue

ASB Bank is under investigation for tax avoidance over investments in Japanese bonds.  Following a preliminary court hearing, the High Court refused ASB access to Inland Revenue internal files about the investigation.
Inland Revenue alleges tax avoidance in respect of foreign exchange losses arising on ASB investments in Japanese government bonds.  In particular, the Revenue is looking closely at the purpose and effect of hedging arrangements used by ASB.  The Bank denies any wrongdoing.
ASB told the High Court there was no tax avoidance, but if there was then no penalties should be imposed because it did not take an “unacceptable tax position” when filing its tax returns.  The Bank was seeking Inland Revenue internal documents to find departmental views which might support its argument that no penalties should be imposed.
The extent of tax avoidance alleged by Inland Revenue was not made public at the preliminary High Court hearing. 
There can be genuine differences of opinion between tax specialists as to the tax effect of a particular transaction.  Even if later found to be in the wrong, a taxpayer can be excused penalties if the tax position taken was “likely or not to be correct”.  This requires evidence that there was objective support for the tax position taken, even if it later proved wrong.
ASB Bank wanted Inland Revenue to hand over all emails, meeting notes and minutes relating to the investigation.  This would include the musings and debates of all staff: senior and junior.
Inland Revenue said there are strong public interest arguments against making disclosure.  Fair and frank exchanges of view between staff would be discouraged if they knew their comments would be disclosed.
Justice Asher ruled against the Bank.  Informal internal expressions of view can only be understood in context.  There may be a myriad of qualifying factors.  Comments may have been based on a lack of knowledge about the subject, or made with a misunderstanding of the background facts, or a particular internal document may be drafted as a contrary view taking the stance of a devil’s advocate.
ASB Bank Ltd v. Inland Revenue – High Court (10.09.14)
14.040