21 October 2015

GST: Staithes Drive v. Inland Revenue

The High Court dissallowed a GST refund of $505,000 where serial tax litigant John George Russell used a complex ownership structure for buying land having as the ultimate beneficial owner a company struck off back in 1996.
Justice Edwards ruled the buyer and seller in a $4.55 million land deal were “associated persons” and no GST refund was payable.  She further ruled the deal amounted to tax avoidance in any event.
The court was told Staithes Drive Development Ltd agreed in February 2006 to purchase a a block of land from Whitby Holdings Ltd for $4.55 million.  Title was transferred immediately without the agreed deposit being paid.  Scheduled contract payments were not paid on time and when paid were not paid in cash.  Instead, credit for payment was made by journal entries between Whitby as vendor and Capital Project Management Ltd, a company controlled by a Mr Mason who was formerly director of Whitby but now director of Staithes Drive.  In the background stood Mr Russell: companies he controlled were ultimate shareholders of both Staithes Drive and Whitby.
When Staithes Drive claimed a GST refund of $505,550 on the purchase from Whitby, Inland Revenue said the two parties were “associated persons” as defined by the Goods and Services Tax Act and Staithes refund was limited to the amount of GST paid by Whitby on its purchase of the land.  This was zero. Whitby was not registered for GST.
Mr Russell argued Staithes Drive and Whitby were not related.  The legal owners of each company were companies he controlled, but his companies were not the beneficial owners, he said.  They held the shares in trust for others: a company called Emmanuel Construction Ltd (in receivership and liquidation) in respect of Staithes Drive and two US residents named as a Mr & Mrs Manning in respect of Whitby.
Justice Edwards said the “voting interests” test for determining associated persons looks at legal ownership of the shares, not beneficial ownership. 
Staithes Drive v. Inland Revenue – High Court (21.10.15)

15.118