Getting Down to Brass Tax: Understanding Asset Protection vs. Tax Avoidance

When might it be ethically incumbent on a lawyer to give advice on the tax consequences of a structure recommended for asset protection purposes? When might the tax adviser’s ‘law-heavy’ advice venture into unqualified legal practice? Our conversation today will touch on these blurred lines, and how important it is to have an effective interdisciplinary approach to advising clients when it comes to asset protection.

The introduction of the general anti-avoidance rules (GAAR) in Part IVA of the Income Tax Assessment Act 1936 (Cth) adds a layer of complexity for lawyers providing asset protection related advice. These rules were designed to prevent schemes that exploit tax loopholes, but they also create a fine line which legal advisors must navigate to ensure that their clients’ asset protection strategies do not inadvertently trigger tax avoidance provisions. This issue is especially relevant in the corporate and commercial law sectors, where asset protection is often intertwined with tax planning.

Criminal Code Act 1995 (Cth)

Tax Agent Services Act 2009 (Cth) (‘TASA’)

• The Duke of Westminster lawfully minimised his tax burden by restructuring payments to his gardener through a covenant, making them tax-deductible. The court upheld this arrangement, affirming that taxpayers may legally structure their affairs to reduce taxes within the law’s limits. Despite objections from tax authorities, Lord Tomlin ruled that the Duke’s actions were legal, distinguishing lawful tax avoidance from tax evasion.

Newton v Federal Commissioner of Taxation [1958] UKPCHCA 1

• The Privy Council introduced the concept of “ordinary family or commercial dealing” to differentiate lawful transactions from tax avoidance under Australia’s section 260 of the 1936 Act. Lord Denning emphasised examining a transaction’s effect to determine if it was aimed solely at tax avoidance. This principle, influencing the current anti-avoidance provisions, recognises legitimate dealings that do not trigger tax avoidance laws.

Hart v Commissioner of Taxation [2018] FCAFC 61

• Mr. Hart’s law firm income had been distributed through a scheme to reduce tax. Justice Bromwich initially ruled that Part IVA clearly applied, with a 50% penalty under section 226 of the 1936 Act, and the Full Federal Court upheld this, finding no error in Bromwich’s reasoning. Mr. Hart’s inability to present a credible counterfactual led to the High Court denying special leave to hear the appeal.

Federal Commissioner of Taxation v Spotless Services Ltd [1996] HCA 34

• The High Court explored whether Part IVA of the 1936 Act could apply to a commercial scheme aimed at maximising tax benefits. For Part IVA to apply, a scheme must involve a “tax benefit” and be undertaken with a dominant purpose of securing that benefit. While legitimate commercial arrangements remain outside Part IVA’s scope, the Court clarified that tax-driven strategies – even if commercially advantageous – may fall within its anti-avoidance provisions.

Federal Commissioner of Taxation v Peabody [1994] HCA 43

• In 1985, Terrence Peabody devised a complex financial arrangement involving his company, TEP Holdings, to buy out partner Mr. Kleinschmidt’s share in Pozzolanic, using creative financing and share restructuring to increase ownership and avoid taxes, ultimately valuing the company at $30 million, with his wife Mrs. Peabody later taxed $888,005 on trust income. The High Court found that the Commissioner’s discretion under section 177F(1) of the 1936 Act to cancel tax benefits is limited to those connected to schemes under Part IVA. The High Court upheld the Federal Court’s decision, finding that Mr. Peabody’s actions were commercially motivated, not aimed at providing Mrs. Peabody with a tax benefit, concluding she did not receive a tax benefit related to a Part IVA scheme.

Toll (FGCT) Pty Ltd v Alphapharm Pty Ltd [2004] HCA 52

• In 1999, Alphapharm imported flu vaccines via a sub-distribution agreement with Ebos, which contracted Toll for logistics without direct dealings with Alphapharm. After state health authorities rejected shipments due to improper temperature control, Alphapharm and Ebos sued Toll for negligence. The High Court ruled that Richard Thomson acted as Alphapharm’s agent, allowing Toll to enforce an exclusion clause in its contract, leading to a judgment in favour of Toll.

Australia and New Zealand Savings Bank Ltd v Commissioner of Taxation [1993] FCA 393

• In 1986, a partnership agreement between banks led to investments in a unit trust, with funds sourced from a non-recourse loan. The partnership incurred interest charges and claimed losses, which were partially allowed by the Commissioner, leading to court proceedings over deductions and assessable income calculations for tax purposes. The court found that the nature of a transaction should be analysed based on the legal rights conferred. In the absence of claims that the transaction is a sham or the application of anti avoidance measures under Part IVA, then the court has to focus on the formal aspects of the transaction.

Minerva Financial Group Pty Ltd v Commissioner of Taxation [2024] FCAFC 28

• Minerva Financial Group reorganised in 2007 into a trust and corporate silo structure, distributing income to non-resident unit-holders to minimise withholding tax liabilities between 2012 and 2015. The Full Federal Court unanimously ruled that Minerva did not enter into any schemes with the dominant purpose of obtaining a tax benefit, thus rejecting the Commissioner’s claims. This case reinforces that obtaining a tax benefit alone does not equate to tax avoidance under Part IVA.

Mylan Australia Holding Pty Ltd v Commissioner of Taxation (No 2) [2024] FCA 253

• In 2007, Mylan agreed to acquire Merck’s global generics business, establishing Mylan Australia and Alphapharm, funded by intercompany debt consistent with Australia’s thin capitalisation limits. The Federal Court ruled in favour of the taxpayer, concluding that Part IVA did not apply to Mylan’s loan arrangement, as MAHPL lacked the dominant purpose of obtaining a tax benefit through its structured borrowing and debt consolidation strategies. The Court also rejected the Commissioner’s counterfactual and double deduction claims.

• Asset protection is a broad field encompassing strategies to minimise risks in commercial and family dealings. It is cross-disciplinary practice that includes tax advice and management, which is not inherently legal but overlaps with legal measures in business and family matters.
• There is confusion surrounding the definitions of tax planning, minimisation, avoidance, and evasion. The key distinction between tax evasion and the other practices is legality, with evasion involving criminal offences, while planning and minimisation are associated with strategies that are legal.
• The GAAR and recent decisions of the Federal Court have reiterated that the test for determining tax liability is objective, and a taxpayer’s subjective intentions are deemed irrelevant under Part IVA.
• Two fundamental inquiries need to be made in relation to Part IVA. The first is determining if there has been a tax benefit, followed by an assessment using the factors in section 177D of the 1936 Act.
• There is a distinction between the “but for” test and the alternate postulate test in analysing tax benefits.
• The distinction between asset protection and tax avoidance is often blurred, particularly for businesses that use company and trust structures.
• Accountants, particularly those who are registered tax agents, are authorised under the TASA to provide tax-related legal advice, but their scope is limited and does not extend to complex legal matters that are not considered tax-related.

• Some lawful tax minimisation strategies include using companies or trust structures to reduce tax liabilities. For example, a sole trader paying high marginal tax rates may benefit from incorporating their business. Another strategy involves setting up a trust with a corporate trustee to allocate income to beneficiaries at the trustee’s discretion.
• Lawyers providing asset protection advice without considering the tax implications for their clients may place themselves at risk of negligence claims.
• Employers may prefer candidates with a Masters degree, especially in technical fields like tax and corporations. Joining relevant professional associations, such as the Tax Institute, can provide valuable resources and networking opportunities in specialised areas like tax law.

Bloom, D. (2016) ‘Tax Avoidance – A View from the Dark Side’, Melbourne University Law Review 

The Tax Institute

NSW Young Lawyers Tax Committee

Working side by side with a client’s tax or financial advisor on a new deal or a new venture is remarkably common and often everyone’s responsibilities on the deal seem nicely partitioned. You’ll do the asset protection advice and the tax advisor will look after the tax effectiveness and efficiency of the structure.

But as our guest today will tell us, those lines can be blurred. When might it be ethically incumbent on a lawyer to give advice on the tax consequences of the structure recommended for asset protection purposes? When might the tax advisor’s “law heavy advice” venture into unqualified legal practice? Our conversation today will touch on those blurred lines and how important it is to have an effective interdisciplinary approach to advising clients when it comes to asset protection.

The introduction of the General Anti Avoidance Rules, what we’ll be calling the GAAR, in Part IVA of the Income Tax Assessment Act 1936 (Cth), what we’ll be calling the “1936 Act”, adds a layer of complexity for lawyers providing asset protection related advice. These rules are designed to prevent schemes that exploit tax loopholes, but they also create a fine line that legal advisors have to navigate to ensure that their clients’ asset protection strategies don’t inadvertently trigger these tax avoidance provisions. The issue can be especially relevant in the corporate and commercial sectors where asset protection is often intertwined with tax planning.

In our discussion today we’ll be delving into how and when asset protection advice can cross over into tax avoidance and we’ll explore the nuances of the GAAR, the importance of what’s called the ‘dominant purpose test’ – and I suppose whether it should really be called that – and how legal advisors can protect their clients while remaining compliant with tax laws.

To guide us through all these issues today, Dr. Mathew Leighton-Daly, an experienced lawyer and consultant, practicing in the areas of corporate, commercial, and taxation law. Having built a wealth of knowledge from both practice and theory, Matthew is an invaluable commentator on the complexities of asset protection and tax avoidance.

Mathew, thank you so much for joining me on Hearsay.

TIP: So Mathew just mentioned that tax evasion can constitute a criminal offence or criminal offences as set out in the Criminal Code. Matthew noted the offence of obtaining property or financial benefits through deception. That’s section 134 of the Commonwealth Criminal Code. We also have section 134.1 of the Commonwealth Criminal Code which prohibits someone dishonestly taking property belonging to the Commonwealth – that includes taxes owed to the ATO. And we have section 134.2 which prohibits instances where a person gains a financial advantage from a Commonwealth entity by being dishonest, such as providing false or misleading information on a tax return. These charges carry a maximum penalty of up to 10 years in prison.

If we can’t attribute a taxpayer’s behaviour to one of those offences, then I guess we’re not in that evasion realm. We’re possibly in the avoidance realm, but yeah, I think it’s the legality, or lack thereof, that demarcates minimisation and avoidance from evasion. Yeah, so a clear line to that extent, at least in theory. Planning, minimisation and avoidance – not so straightforward, to the extent that evasion is straightforward. There’s an old case, and it’s still quoted, and I think it still has work to do, at least at common law, known as the Duke of Westminster case. And in this case, Lord Tomlin famously said “every man is entitled if he can to arrange his affairs so that the tax attaching under the appropriate Acts is less than it otherwise would be. If he succeeds in ordering them so as to secure that result, then, however unappreciative the Commissioners of Inland Revenue or his fellow taxpayers may be of his ingenuity, he cannot be compelled to pay an increased tax” Now that’s, at common law I guess, that is planning, that is minimisation, that is not avoidance.

TIP: So we’ve been talking about an English case here, the Duke of Westminster, it’s still good law in Australia, and the full citation for that one is Inland Revenue Commissioners v. Duke of Westminster [1936] A.C. 1. Now in that case, the Duke of Westminster figured out a way to reduce his tax liability. Instead of continuing to pay his gardener a traditional wage from his post tax income, he stopped paying the gardener a regular salary and set up what was called in those days a covenant. And this covenant allowed him to pay the gardener the same amount as he was paying him in wages at specified intervals, but under the tax laws at the time, those payments were tax deductible for the Duke. As a result, the Duke lowered both his taxable income and his liability for income tax and other taxes. The Inland Revenue Service challenged this arrangement, arguing it was a form of tax evasion masked as legal tax avoidance, but the court sided with the Duke. The Judge Lord Tomlin famously ruled that taxpayers are entitled to structure their affairs in a way that minimises their tax burden, as long as it remains within the bounds of the law. He emphasised that even if the tax authorities or fellow taxpayers disapproved, the Duke had done nothing illegal. This ruling became a landmark decision in tax law, reinforcing the distinction between legal tax avoidance and illegal tax evasion, and it continues to influence discussions about tax strategies to this day. Although, the anti avoidance provisions have substantially muddied the waters about the continuing applicability of the Duke of Westminster’s case.

Unfortunately, with the enactment of provisions such as the GAAR – as you’ve defined it, David – I think the distinction has been blurred. And even in the explanatory materials to the bill that is now enacted in the form of Part IVA – I think it was John Howard who said he was acutely aware that views on tax avoidance differ. So, it started off with – at least a common law – this distinction between planning or minimisation and avoidance. The GAAR, I think, has blurred it.

TIP: Okay, so we just talked about the objective factors that a decision maker has to have regard to in determining whether something is a scheme for the purpose of obtaining a tax benefit under section 177D. It’s subsection 2 of that section under the general anti avoidance regime. And for completeness, here are all of those factors listed out:

• so, the first factor is the method by which the scheme was initiated or executed;
• then the form and substance of the scheme; 
• the timing of the scheme’s initiation and the duration for which it was implemented;
• the outcome regarding the enforcement of this Act that the scheme would achieve if the part were not in effect – in other words, what would the result of the scheme be but for the general anti avoidance provisions?;
• any changes in the financial status of the taxpayer resulting from or expected to result from or reasonably anticipated to result from the scheme;
• any changes in the financial status of other individuals connected through business, family, or other relationships to the taxpayer;
• any additional consequences for the taxpayer or for any of the related business, family, or other individuals resulting from the initiation or execution of the scheme;
• and finally, the type of relationship, whether it’s a business relationship, family relationship or some other kind, between the taxpayer and those individuals that may also be affected by the scheme.

None of those factors are what either the advisers or the clients intended to achieve with the scheme, right?

TIP: We’ve also just mentioned Newton’s case. We’re going to continue to talk about Newton’s case throughout the episode, so it’s worth spending a bit of time understanding it now. The full citation is Newton v Federal Commissioner of Taxation 98 CLR 1. The Privy Council introduced the concept of ordinary family or commercial dealing in the context of tax avoidance, a principle that continues to influence Australian tax law. The case dealt with section 260 of the 1936 Income Tax Assessment Act, which was actually a precursor to Part IVA, the current general anti avoidance provisions. And although section 260 itself didn’t explicitly refer to what we call ordinary family or commercial dealings, the concept was established by the Privy Council in Newton’s case. Lord Denning in that case famously stated that to apply the section, one must focus on the arrangement’s effect, regardless of the motives behind it. If the transaction was implemented specifically to avoid tax, it would fall within the anti avoidance provision. But, if the transaction could be explained as part of an ordinary business or family dealing without being labeled as a tax avoidance scheme, then it wouldn’t trigger the provision. Lord Denning provided examples of what could be considered ordinary family or commercial dealings, like the transfer of shares with dividends attached, converting a private company into a non private company, or a father declaring a trust in favour of his wife and daughter – remember it was 1958, fairly gendered language in these cases. These examples illustrated situations where legitimate family or business transactions could occur without being classified as tax avoidance. Newton’s case is now embedded in section 100A of the Income Tax Assessment Act and it influences the interpretation of Australia’s general anti avoidance provisions to this day. Although, as Mathew has said, we no longer look for schemes that, in the words of Lord Denning, are “artificial, blatant, or contrived.”

TIP: Section 10 of the Legal Profession Uniform Law (“LPUL”) prohibits any entity from engaging in legal practice in New South Wales unless it’s a qualified entity. Equivalent provisions exist in the other uniform law states, and so too in the non-uniform law states, although there might not be section 10. The LPUL says that to engage in legal practice is to practice law or provide legal services, but doesn’t include policy work like developing and commenting on legal policy. Some cases have helped us to clarify what it means to engage in legal practice and to provide legal services. If someone performs actions typically done by a solicitor and does so in a way that suggests they are a solicitor, then it might be considered to be acting as one – the old ‘walks like a duck, and quacks like a duck’ test. Giving advice on the legal character and prospects of litigation, especially after reviewing evidence, clearly constitutes legal practice, as it implies that the person offering the advice is qualified to do it. A person who’s not a qualified legal practitioner will be deemed to be practicing law if they perform tasks restricted by law to those with legal training. Charging a fee for legal work can indicate engagement in legal practice, but isn’t necessarily a condition for such a finding. So, you don’t need to charge your clients in order to be held to be unlawfully engaging in legal practice. And finally, the cases indicate that the so-called core of legal practice is advising individuals on their specific legal situations and preparing documents that affect their legal rights that are tailored to their unique needs. The maximum penalty for engaging in legal practice without proper qualification is a fine of 250 penalty units, that’s about $28,000, imprisonment for up to two years, or both. So you can certainly see how, arguably, a tax advisor falls foul of these provisions when they advise on the specific legal rights of a particular individual or company or prepare documents that affect those specific legal rights when advising or preparing certain tax structures.

In terms of working through the GAAR, my professional observation is people just talk about the commerciality. And as we’ve discussed – and it was particularly Hart‘s case, I think, and Spotless Services before it, actually, now that I think of it, they both make the point that overall commerciality is not enough – you’ve got to look at the steps along the way. And similarly, there’s this common reference to Newton‘s case and the wording in that case – “blatant, artificial, and contrived.” That is often thrown around, you know, “well, this scheme is not ‘blatant, artificial and contrived.’” That’s not the test. That’s an old case. And although the explanatory memorandum accompanying the bill to introduce Part IVA describe the test in 177D as being similar to Newton’s case, I just think you have to look at 177D. And some of the other seminal cases – Peabody, I’ve mentioned Hart already – they talk about,  you must consider all eight factors there in 177D. It’s not relevant that every factor be proven in respect of every scheme. Indeed, it was held in Hart that the presence of one factor alone may be sufficient to constitute a dominant purpose, and the actual subjective purpose of any relevant person is not a relevant matter as we’ve discussed ad nauseum now.

TIP: So Matthew just mentioned the article written by David Bloom KC, who was a QC at the time he wrote the article, called ‘Tax Avoidance – A View from the Dark Side.’ In that article, Bloom argued that Part IVA of the Income Tax Assessment Act is incompatible with the Duke of Westminster case, as illustrated in the Spotless Services case. Now in Spotless Services, the majority noted that while the Privy Council echoed Lord Tomlin’s statement that individuals are entitled to arrange their affairs to minimise tax liabilities, as was said in the Duke of Westminster, this principle holds no relevance in cases governed by the general anti avoidance provisions in Part IVA. Instead, Part IVA has to be treated as an integral part of the tax law, requiring consideration of both the form and substance of a transaction when assessing a party’s dominant purpose under Section 177D, basically arguing the Duke of Westminster no longer applies. Once it’s determined that Part IVA doesn’t apply, then there’s no justification for prioritising substance over form in tax assessments. This principle was reinforced in the case of Australia and New Zealand Savings Bank Ltd v Commissioner of Taxation [1993] FCA 393, where it was said that the nature of a transaction should be analysed based on the legal rights conferred. In the absence of claims that the transaction is a sham or the application of anti avoidance measures under Part IVA, then the court has to focus on the formal aspects of the transaction. So, while the substance can be considered when determining the applicability of Part IVA, once Part IVA is determined not to be applicable, the focus should then shift to the form of the transaction rather than the substance. We’ll leave a link to David Bloom KC’s article in the show notes.

I guess another important one by reference to some of the recent cases – and there are a couple of Federal Court cases which I didn’t touch upon in my article, partly because of the timing and partly on reflection, because they are more to do with very large corporate restructures – I made a reference earlier to this ‘alternate postulate’ test, which is used in relation to the analysis of any tax benefit. It’s important that we understand that that is not the same thing as a ‘but for’ test. Now, previously it was considered to be a ‘but for’ test. So Minerva Financial Group Pty Ltd v Commissioner of Taxation [2024] FCAFC 28 – that, I think, confirms that we’re not looking at a ‘but for’ test in relation to the operation of Part IVA. And it’s significant because I was looking at a precedent letter for CPA Australia – which they recommend to their members to send out to advise a client about Part IVA risks – and they refer to a ‘but for’ test.

TIP: So the distinction between tax avoidance and tax evasion has never been straightforward, but it was a little easier to understand in the past. Historically, ‘tax avoidance’ has been seen as a legally permissible strategy, meaning individuals could minimise their tax liabilities legally, while ‘tax evasion’ was the term applied to illegal activity. But in recent years, the line between these two concepts has been blurred, mainly by the application of provisions like Part IVA. The confusion now persists to such an extent that some tax officials now prefer the terms ‘compliant’ and ‘non compliant’, instead of distinguishing between avoidance and evasion. In the past, tax avoidance referred to taxpayers using legitimate methods or schemes to reduce their tax obligations, without implying any intentional wrongdoing, like in the Duke of Westminster’s case. It simply meant paying less tax than you would otherwise be required to. This practice is also often called tax minimisation, and it represents the ultimate goal of tax planning. Tax planning in its most benign sense can be viewed as taking advantage of tax concessions in line with the Parliament’s intentions. Most investors, shareholders in companies, owners of investment property likely engage in some form of tax planning even if they’re unaware of it. 

A really simple example is the use of discretionary family trusts as vehicles for holding investment properties. Over the past 40 years, since the introduction of the GAAR, tax avoidance has taken on a negative connotation. It’s now difficult to apply the term tax avoidance to legitimate and lawful strategies employed by taxpayers because of the general anti avoidance provisions that make tax avoidance something avoidable. By contrast, tax evasion is always illegal. It involves culpable actions or omissions by the taxpayer, and it’s considered fraud, punishable under the Commonwealth Criminal Code. Tax evasion usually includes illegal practices like underreporting income, making false statements on your tax return, or overstating deductions or exemptions to avoid paying taxes. Individuals caught evading taxes can receive significant penalties like hefty fines or in serious cases custodial sentences. 

In 1981, John Howard spoke to Parliament’s intention for the function of the general anti avoidance provisions in the second reading speech for the act that introduced the provision. Now in that speech, Mr. Howard said, I quote, “we’re acutely aware that the term tax avoidance means different things to different people. Reasonable men and women are bound to differ on this crucial question and on the appropriate tests for determining what behaviour a general anti avoidance provision ought to prescribe.”

While John Howard further mentioned that the provisions should be limited to “blatant, artificial or contrived” arrangements, these terms didn’t make it into the statute and they’ve generally been overlooked by the courts in interpreting the anti avoidance provisions. Even with the intention of making the distinction between evasion and avoidance clearer, we don’t really have a clear answer to this question nearly 40 years on. 

Some of our listeners are probably thinking, “well, what can you do to lawfully minimise your tax?” Can you give us an example of a lawful tax minimisation strategy?

TIP: So Mathew just mentioned the TASA. You can become a registered tax agent under the TASA if you prepare income tax returns for 10 or more clients and you’re an individual engaged in a business or occupation that includes preparing income tax returns. The eligibility requirements for a tax agent can be found in section 20.5. Individuals have to meet some pretty basic criteria – they have to be 18 years old, and they have to be a fit and proper person, just like a lawyer, who complies with the requirements set out by the regulations. Tax agents can be individuals, but they can also be partnerships or companies, and if they’re companies, they obviously can’t be an external administration. To provide tax agent services for a fee or engage in any related activities to providing tax agent services for a fee, you have to be registered with the Tax Practitioners Board and when you register, you register for a minimum of three years. The Federal Government recently released a consultation paper reviewing the registration requirements for tax practitioners. focusing on requirements for education, qualifications and experience both for new practitioners and existing ones. The proposals aim to strengthen regulatory frameworks for tax agents in response to issues raised by the PwC tax scandal. One of the key points in the consultation paper is whether legal practitioners who provide tax agent services should be required to register with the Tax Practitioners Board. Currently legal practitioners are exempt from TPB registration unless their services include preparing or lodging tax returns. The consultation seeks input from the public and from the profession on whether this exemption should continue or whether legal practitioners offering tax advice should also be regulated by the TPB, regardless of whether or not they prepare returns. CPA Australia made a submission in response to the consultation paper and said that legal professionals providing complex or so called “aggressive” tax advice might not face the same oversight as registered tax agents, which could lead to asymmetry and penalties if both a lawyer and a tax agent work on the same case. CPA Australia also highlighted that tax issues rarely reach legal profession boards and questioned the effectiveness of the current regulatory system for lawyers in tax matters. It’s an interesting question because in other areas of interdisciplinary practice where lawyers work alongside non lawyer practitioners, there’s a general trend of reducing the need for multiple registrations. For example, only recently we saw that lawyers who provide similar services to migration agents no longer have to be registered as migration agents. Introducing a requirement for lawyers to be registered with the Tax Practitioners Board would be going in the opposite direction to some of these changes.

So what does all that mean? Fundamentally, tax agents who are non-lawyers can give a certain amount of tax related advice, but it is limited as compared to what a lawyer can do. I think the advice on the legal effect of transactions, the drafting of transactional documents and advice on general or specific anti avoidance provisions ought to come from lawyers.

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