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Baxter & Anor v. Chief Commissioner of Pay-roll Tax (N.S.W.).

Judges:
Yeldham J

Court:
Supreme Court of New South Wales

Judgment date: Judgment handed down 26 November 1986.

Yeldham J.

These appeals raise for consideration the complex and difficult grouping provisions of Pt IVA of the Pay-roll Tax Act 1971, and in particular sec. 16E and 16H. The plaintiffs, who are solicitors and partners in the firm of W.A. Baxter & Co., appeal against the decision of the defendant dated 30 May 1985 disallowing objections against the assessment of their liability for payment of pay-roll tax for the years ended 30 June 1977-1984 inclusive.

In each of the years in question W.A. Baxter & Co. (which I will call ``the firm'') employed solicitors in its business and prior to June 1977 it also employed secretarial and other like staff. On 23 June 1977 the Baxter Co. Partnership Trust was established pursuant to a deed of settlement of that date between a settlor and a company called Valga Pty. Limited (``Valga'').

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The latter was incorporated on 9 May 1977 and at all material times its directors have been George Henry Paul and Barry James Paroz who are partners in a firm of chartered accountants now known as Paul Paroz Brett & Associates (formerly G.H. Paul Paroz and Associates) (``Paul Paroz''). At all material times also the sole shareholders in Valga were Messrs Paul and Paroz. Clause 8 of the deed of settlement vested in the senior partner for the time being of the firm W.A. Baxter & Co. the power of appointing a new trustee and of removing any trustee. The beneficiaries under the trust were members of the family of the partners of the firm. Since June 1977 Valga has not engaged in any activities other than those which it has undertaken in its capacity as trustee of the Baxter Co. Partnership Trust (``the trust''). Those activities have been the provision of secretarial, management and administrative services and the hiring of office equipment to the firm. Each year an agreement was entered into between Valga and the firm for the leasing of specified office equipment and furniture at defined rents, payable half-yearly, and for the payment by the firm of an agreed lump sum, in consideration of which Valga agreed ``to provide the hirers with all such qualified clerical, secretarial and bookkeeping staff and office cleaners as the hirers may from time to time require'' and to ``pay all relevant wages, including overtime, if any, any pay-roll tax, holiday pay and sickness benefits... ''. The day-to-day management of the activities of Valga with respect to the provision of services was at all times administered by the partners of the firm and not by the directors of Valga. Neither the latter nor Messrs Paul and Paroz have at any time had any beneficial interest in the business carried on by Valga in its capacity as trustee. The business of Valga has at all times been carried on independently of that conducted by the accounting firm of Paul Paroz. The sole connection between the two businesses lay in the fact that the two partners of Paul Paroz were the shareholders and directors of Valga. No fees were charged by Paul Paroz to either Valga or the firm in respect of the functions performed by Messrs Paul and Paroz as directors of Valga. Paul Paroz provided accounting services to the firm and to Valga, these being the preparation of accounts and taxation returns, and in respect of such work the accountants charged their usual professional fees. So also from time to time the firm has provided legal services to Paul Paroz and to the individual partners and in those cases it too has charged professional fees on the usual basis. The activities of Valga with respect to the provision of services to the firm have been performed at the premises of the latter, and these were separate and distinct from the offices of Paul Paroz. During the relevant period Valga maintained a separate trading bank account with respect to its activities as trustee. The normal practice was that all cheques were signed by a partner of the firm. Messrs Paul and Paroz occasionally signed cheques, but usually only when no partner of the firm was available to do so.

In the year 1980 the partners in Paul Paroz established a trust pursuant to a deed of settlement between a settlor and a company called Gemmi Pass Pty. Limited (``Gemmi Pass'') as trustee. The name of the trust was ``Conadilly Secretarial Trust'' (``Conadilly''). The directors of Gemmi Pass have at all material times been the wives of the partners in Paul Paroz and they have been the sole shareholders. Since its incorporation on 8 February 1980, Gemmi Pass has not engaged in any activities other than those which it has undertaken in its capacity as trustee of Conadilly. These activities have been the provision of equipment, secretarial, management and administrative services to the firm of Paul Paroz. At no time did Valga provide any services to Gemmi Pass and at no time did the latter provide services to Valga. There was no connection between the two businesses.

Part IVA of the Pay-roll Tax Act was introduced in 1975. It is obviously designed to prevent the splitting of businesses, and to avoid other devices for the minimising of any liability for pay-roll tax. Sections 16A-16H inclusive should be set out in full. They are in these terms:

    16A Interpretation

  • In this Part, ``business'' includes -
    • (a) a trade or profession;
    • (b) any other activity carried on for fee, gain or reward; and
    • (c) the activity, carried on by an employer, of employing one or more persons where that person performs or

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      those persons perform duties for or in connection with another business.

    16B Grouping of corporations

  • For the purposes of this Act, two corporations constitute a group if they are, by reason of section 7(5) of the Companies (New South Wales) Code to be deemed, for the purposes of that code, to be related to each other.

    16C Grouping where employees used in another business

  • For the purposes of this Act, where -
    • (a) an employee of an employer, or two or more employees of an employer, performs or perform duties solely or mainly for or in connection with a business carried on by that employer and another person or other persons or by another person or other persons; or
    • (b) an employer has, in respect of the employment of, or the performance of duties by, one or more of his employees, an agreement, arrangement or undertaking (whether formal or informal, whether expressed or implied and whether or not the agreement, arrangement or undertaking includes provisions in respect of the supply of goods or services or goods and services) with another person or other persons relating to a business carried on by that other person or those other persons, whether alone or together with another person or other persons,

    that employer and -

    • (c) each such other person; or
    • (d) both or all of those other persons,

    constitute a group.

    16D Grouping of commonly controlled businesses

  • (1) A reference in this section to two businesses does not include a reference to two businesses both of which are owned by the same person, not being a trustee, or by the trustee or trustees of a trust.
  • (2) For the purposes of this Act, where the same person has, or the same persons have together, a controlling interest under subsection (3) in each of two businesses, the persons who carry on those businesses constitute a group.
  • (3) For the purposes of subsection (2), the same person has, or the same persons have together, a controlling interest in each of two businesses if that person has, or those persons have together, a controlling interest under any of the following paragraphs in one of the businesses and a controlling interest under the same or another of the following paragraphs in the other business:
    • (a) a person has, or persons have together, a controlling interest in a business, being a business carried on by a corporation, if the directors, or a majority of the directors, or one or more of the directors, being a director or directors who is or are entitled to exercise a majority in voting power at meetings of the directors, of the corporation are or is accustomed or under an obligation, whether formal or informal, to act in accordance with the directions, instructions or wishes of that person or of those persons acting together;
    • (b) a person has, or persons have together, a controlling interest in a business, being a business carried on by a corporation that has a share capital, if that person or those persons acting together may (whether directly or indirectly) exercise, control the exercise of, or substantially influence the exercise of, 50 per centum or more of the voting power attached to voting shares issued by the corporation;
    • (c) a person has, or persons have together, a controlling interest in a business, being a business carried on by a partnership, if that person or those persons -
      • (i) owns, or own together (whether or not beneficially) 50 per centum or more of the capital of the partnership; or
      • (ii) is, or are together, entitled (whether or not beneficially) to 50 per centum or more of any profits of the partnership;
    • (d) a person has, or persons have together, a controlling interest in a

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      business, being a business carried on under a trust, if that person (whether or not as the trustee of another trust) is the beneficiary, or those persons (whether or not as the trustees of another trust) are together the beneficiaries, in respect of 50 per centum or more of the value of the interests in the trust firstmentioned in this paragraph;
    • (e) a person has a controlling interest in a business if, whether or not he is a trustee of a trust, he is the sole owner of the business or persons, being two or more trustees of a trust, have a controlling interest in a business if they are the owners of the business.
  • (4) Where a corporation has a controlling interest under subsection (3) in a business, it shall, for the purposes of subsection (3), be deemed to have a controlling interest in any other business in which another corporation that is, by reason of section 7(5) of the Companies (New South Wales) Code to be deemed, for the purposes of that Code, to be related to it has a controlling interest.
  • (5) Where -
    • (a) a person has, or persons have together, a controlling interest under subsection (3) in a business; and
    • (b) the person or persons who carries or carry on that business has or have such a controlling interest in another business,

    the person or persons referred to in paragraph (a) shall, for the purposes of subsection (3), be deemed to have a controlling interest in the business referred to in paragraph (b).

  • (6) Where -
    • (a) a person is a beneficiary under a trust; or
    • (b) two or more persons together are beneficiaries under a trust,

    in respect of 50 per centum or more of the value of the interests in that trust and the trustee or trustees of that trust has or have under subsection (3) a controlling interest in a business, that beneficiary or those beneficiaries shall, for the purposes of subsection (3), be deemed to have a controlling interest in that business.

    16E Smaller groups subsumed into larger groups

  • (1) Notwithstanding any other provision of this Part (except subsection (2)), where a person is, whether or not by virtue of this subsection, a member of two or more groups (each of which is in subsection (2) referred to as a smaller group), all of the members of those groups constitute, for the purposes of this Act, one group.
  • (2) Except for the purpose of determining whether a group is constituted under subsection (1), a group which, but for this subsection, would be a smaller group ceases to be a group if its members are members of a group constituted under subsection (1).

    16F Grouping provisions to operate independently

  • The fact that a person is not a member of a group constituted under a provision of this Part does not prevent that person from being a member of a group constituted under another provision of this Part.

    16G Beneficiaries under discretionary trusts.

  • A person who, as the result of the exercise of a power or discretion by the trustee of a discretionary trust or by any other person or by that trustee and other person, may benefit under that trust shall be deemed, for the purposes of this Part, to be a beneficiary in respect of 50 per centum or more of the value of the interests in that trust.

    16H Exclusion of persons from groups

  • (1) Where the Chief Commissioner is satisfied, having regard to the nature and degree of ownership or control of the businesses, the nature of the businesses and any other matters that he considers relevant, that a business carried on by a member of a group is carried on substantially independently of, and is not substantially connected with the carrying on of, a business carried on by any other member of that group, the Chief Commissioner may, by order in writing served on that firstmentioned member, exclude him from that group.
  • (2) The Chief Commissioner shall not, under subsection (1), make an order so as to exclude a person from a group on and from a date if that person is or was on that date a

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    corporation which, by reason of section 7(5) of the Companies (New South Wales) Code is to be deemed, for the purposes of that Code, to be related to another corporation which is a member of that group.
  • (3) Notwithstanding any other provision of this Part, an order under subsection (1) shall have effect according to its tenor on and from the date specified in the order (being a date that is the date of the order or before the date of the order) as the date on and from which the person referred to in the order is or shall be deemed to have been excluded from the group so referred to.

The defendant purported to apply in relation to the plaintiffs the grouping provisions of the Act, and his reasons for doing so are summarised in a letter dated 19 May 1986 from the State Crown Solicitor to the firm which said, inter alia:

``1. The application of Part IVA (the grouping provisions) of the Pay-roll Tax Act is not discretionary but mandatory; where two or sometimes more persons fall within the terms of Sections 16B, 16C or 16D(3), with or without the operation of Section 16G, they constitute a group for Pay-roll tax purposes.

2. Accordingly, the four businesses carried on respectively between 1st July 1976 and 30th June, 1984, by

  • (a) The partnership t/a W.A. Baxter & Co. - Solicitors' practice.
  • (b) Valga Pty. Ltd. trustee for Baxter Co. partnership trust - `service' trust to above practice.
  • (c) The partnership t/a Paul Paroz Brett & Assoc. - Chartered accountants' practice.
  • (d) Gemmi Pass Pty. Ltd. trustee for Conadilly Secretarial Services Trust - `service' trust to above accountancy practice.

give rise to the following `groups' within Part IVA:

  • Group 1: Valga Pty. Ltd. (employer) carrying on service trust business and Solicitors' partnership carrying on legal practice (Section 16C).
  • Group 2: Valga Pty. Ltd. (service trust business) and accountancy partnership carrying on accountancy practice: Messrs. Paul and Paroz together controlled Valga Pty. Ltd. (Section 16D(3)(b)) and the accountancy partnership (Section 16D(3)(c)): see Section 16D(2).
  • Group 3: Gemmi Pass Pty. Ltd. (service trust business) and accountancy partnership (accountancy practice): certainly by reason of Section 16C and probably also by reason of Section 16D(3)(a).
  • (a) The accountancy partnership being a member both of Group 2 and Group 3, Section 16E(1) requires those two groups to be grouped into a larger group: i.e. Group 4, comprising the accountancy partnership, Gemmi Pass Pty. Ltd., Valga Pty. Ltd. and the solicitors' partnership
  • (b) Similarly, Valga Pty. Ltd. being a member both of Group 1 and Group 2, those two groups must be grouped (Section 16E(1)) into a larger group: i.e. Group 5, constituted by Valga Pty. Ltd. the solicitors' partnership and the accountancy partnership.
  • (c) As Groups 4 and 5 have several members in common, Section 16E(1) requires all their members to be grouped into a single group, Group 6.
  • (d) Accordingly, the solicitors' partnership, Valga Pty. Ltd., Gemmi Pass Pty. Ltd. and the accountancy partnership are all subsumed into this single group, Group 6, by virtue of Section 16E(1).

4. As the Chief Commissioner pointed out in his letter to you of 23rd August, 1984 Section 16H(1) `does not provide for the exclusion of groups'. That is, once Group 1 and Group 3 are linked by the common control of the accountancy partnership and Valga Pty. Ltd., those groups disappear and a new group is constituted comprising the persons operating the 4 businesses.

5. Moreover, again as the Chief Commissioner pointed out in that letter, and in his subsequent letter of 20th November 1984 Section 16H(1) only authorises him to exclude one member of the group (here either the legal partnership or the

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accountancy partnership, whichever is the applicant) if that member can satisfy him that its business is carried on substantially independently of each and is not substantially connected with any other member of that group.

6. It seems unlikely that the applicant, be it W. Baxter & Co. or Paul Paroz, Brett & Associates, will be able to satisfy the Commissioner that its business is `carried on substantially independently of and is not substantially connected with' its own service trust. Certainly such independence has not been demonstrated to date and, having regard to the application (and implication) of Section 16C, it seems unlikely that it could be so demonstrated. In any event the connection between the accountancy practice and its service trust has been conceded.

7. It would follow that even if the legal practice and the accountancy practice were independent of each other, and the two service businesses were independent of each other, there would be no room for the application of Section 16G(1) because of the inter-connection of each professional practice with its own service trust...''

For the purposes of the present appeal the Chief Commissioner agreed that:

``(1) he refused to make any order pursuant to section 16H for the reason that he was of the view that he had no power under that section to make any order;

(2) he was of the view that the business carried on by Valga Pty. Limited was carried on substantially independently of, and was not substantially connected with the carrying on of, the businesses carried on by: -

  • (a) G.H. Paul Paroz & Associates, and
  • (b) Gemmi Pass Pty. Limited;

(3) he was of the view that the business carried on by W.A. Baxter & Co. was carried on substantially independently of, and was not substantially connected with the carrying on of, the businesses carried on by: -

  • (a) G.H. Paul Paroz & Associates, and
  • (b) Gemmi Pass Pty. Limited.''

The plaintiffs agreed that:

``(1) at all relevant times Messrs Paul and Paroz, as directors of Valga Pty. Limited, acted in accordance with the wishes of the partners of W.A. Baxter & Co.;

(2) Clause 8 of the deed governing the Baxter Co. Partnership Trust vests in the senior partner of W.A. Baxter & Co. the power of appointing a new trustee and removing Valga Pty. Limited as trustee. Apart from this there was no legal power which any of the partners of W.A. Baxter & Co. could exercise to compel Messrs Paul and Paroz, as directors of Valga Pty. Limited, to act in accordance with their wishes.''

It is apparent that the businesses carried on by the partnership, and the Baxter Co. Partnership Trust, on the one hand, and those conducted by Paul Paroz and the Conadilly Secretarial Services Trust on the other, are not in fact connected. The contrary was not argued.

The critical question which arises is whether, assuming the Commissioner properly applied the provisions of the Act to group the persons carrying on the four separate businesses as members of a single group, he has correctly refused to exclude from that single group the partners of the firm and/or the persons trading as Paul Paroz. The plaintiffs submit that, as a matter of construction of sec. 16H, it should operate in the circumstances of the present matter so that the end result produced, as one group, the firm W.A. Baxter & Co. with its service company, of which Valga is trustee, and, as a second group, Paul Paroz and its service entity, of which Gemmi Pass is trustee, both of these groups being excluded from any larger group. Any consequent reduction in pay-roll tax which would result is not a matter with which I am concerned, it being agreed that, if the plaintiff should succeed, the appropriate orders would be to remit the assessments back for reconsideration.

It is not necessary to consider in any detail the operation of the various provisions of Pt IVA which led the Chief Commissioner to the view that the groups defined in the Crown Solicitor's letter of 19 May 1986 existed. Nor is it necessary to consider whether or not, for example, the provisions of sec. 16D(3)(b) apply in the case of a corporation which acts as trustee. There is no doubt that by the operation

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of one or more of the sections which I have earlier set out, the firm W.A. Baxter & Co. and Valga Pty. Limited constituted one group; Paul Paroz and Gemmi Pass Pty. Limited constituted a second group; and Paul Paroz and Valga were probably a third group. If it be assumed that sec. 16E operates prior to the point of time when sec. 16H might, in an appropriate case, be invoked then, in its application to the present case, there would, in the result, be a single group by virtue of the operation of sec. 16E, comprising the firm W.A. Baxter & Co., Valga, Paul Paroz and Gemmi Pass Pty. Limited. It should here be said that ``person'' is defined in sec. 3 to include a company.

The critical question concerns the construction and operation of sec. 16H. The attitude of the Chief Commissioner is as set out in para. 5, 6 and 7 of the letter of 19 May 1986. Although Group 2 as defined in that letter was ``marginally in issue'' (to adopt the expression of senior counsel for the plaintiffs), because of a submission made by him that sec. 16D(3)(b) and (c) did not apply to companies acting as trustees, having regard to the express reference to trusts in sec. 16D(3)(d) and (e) and in subsec. (6), I propose to assume, having regard to the conclusion which I have reached concerning the construction of sec. 16H, that the appropriate groups are those for which the defendant contends.

It is the argument summarised in para. 5 of the letter which the plaintiffs principally attacked. Mr Hill, senior counsel for the plaintiffs, submitted that, having regard to the operation of sec. 21(b) of the Interpretation Act 1897 (which provides that, unless the contrary intention appears, words in the singular shall include the plural and words in the plural shall include the singular), there being, in Pt IVA of the Pay-roll Tax Act, no contrary intention, sec. 16H should be construed to entitle the Commissioner to exclude one or more businesses from a particular group if satisfied they are substantially independent of businesses carried on by any other members of that group. Counsel argued that it was only such a construction that would enable the section to be construed in the broad way which was necessary in order to alleviate hardships and anomalies which would otherwise be created by the operation of other sections - see generally
Commr of Pay-roll Tax v. R.G. Elsegood & Co. Pty. Ltd. (1983) 1 N.S.W.L.R. 223. Mr Hill submitted that, so interpreted, sec. 16H would here empower the defendant to so act as to leave two groups together, each excluded from the large group containing four persons, one being the firm W.A. Baxter & Co. with its service entity Valga, and the other being the accounting partnership Paul Paroz, with its service entity Gemmi Pass.

In the letter dated 19 May 1986 (in a paragraph which I omitted), reference was made by the Crown Solicitor to three authorities, two only of which were relied upon by counsel for the defendant. These were
Mead Packaging (Aust.) Pty. Ltd. v. Commr of Pay-roll Tax 78 ATC 4164, where Rath J., in a detailed and careful judgment, considered the operation in that case of sec. 16H. However, as was conceded before me, the question of whether or not that section was to be construed as the present plaintiffs submit was not argued or decided, and hence I need not refer to it. The second case was
John French Pty. Ltd. v. The Commr of Pay-roll Tax (1984) 1 Qd.R. 125, a decision of the Full Court of the Supreme Court of Queensland. Once again the judgments deal in a helpful way with the operation of the grouping provisions of the Queensland statute which, for all relevant purposes, are the same as those with which I am presently concerned. In both of the cases referred to there were ultimately three entities forming one group by the application of sec. 16E and the particular taxpayer sought to be removed from the group of three. It was held that the requisite satisfaction which was necessary under sec. 16H must be had in respect of each other member of the group.

The question of whether sec. 16H should be construed as the plaintiffs assert in the present case does not appear to have been the subject of any decision. On behalf of the defendant Mrs Horler submitted that it operated only to exclude a member of a group, in an appropriate case, where the business carried on by that member is substantially unconnected with the business carried on by every other member of the group and that, in a case such as the present, the legal firm W.A. Baxter & Co. could as a matter of law be excluded from the overall group containing the four ``persons'' only if it could be shown that it was carried on substantially independently of and was not substantially connected with every other person in the group, including Valga. In other words

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the defendant argued that the expression ``any other member of that group'' in sec. 16H meant ``each other member of that group'', and that to give effect to the arguments of the plaintiff would be to deny to sec. 16E any real operation in a case such as the present. In written submissions sent to me after I had reserved judgment Mrs Horler argued (inter alia) that:

``... even if it were, as a matter of statutory interpretation, possible so to construe s. 16H(1), it should not be so construed, since to exclude the members of a sub-group in effect would be not only notionally to resurrect the sub-group which s. 16E(1) and (2) has eliminated but also, since s. 16E(2) has applied to put an end to the separate consideration of the eliminated sub-groups for all purposes of the Act, it would preclude the Chief Commissioner from applying s. 161 and assessing the sub-group (here Baxter & Co. and Valga Pty. Limited) even though it as a sub-group has a pay-roll in excess of the exemption limit... Such a construction of s. 16H(1) would be inconsistent with allowing any coherent function to s. 16E and its plainly intended role to s. 161.''

In answer to this counsel for the plaintiffs argued:

``The plaintiffs' submission does not actually or notionally resurrect any sub-group (whatever that would mean). The two remaining members of the group of four would remain members of that group. The two excluded members, not being members of the group of four, are no longer prevented by s. 16E(2) from forming a group and accordingly do so under s. 16C. It is submitted that neither s. 16E, s. 16I nor any other provision of the Pay-roll Tax Act indicates an intention that the operation of the Interpretation Act should be excluded in applying s. 16H(1). Indeed it is only by reading the singular as including the plural that Part IVA is given a rational operation.''

In construing sec. 16H it is necessary to keep firmly in mind that the grouping provisions to be found in Pt IVA cast an exceptionally wide net and potentially give rise to a great many unintended grouping situations. The provisions of sec. 16H(1) were intended to provide a balance against this to prevent injustice from being done in particular cases and hence, in my view, it should not be given a narrow construction.

I see no reason, either in principle or in the language used in the relevant section, why the latter cannot be construed, with the aid of sec. 21(b) of the Interpretation Act 1897, so as, for example, to remove two members from a group of four. Such a result has logic and common sense on its side and would permit, in a case like the present, an absurd and plainly unintended consequence to be avoided. By treating words in the singular as including those in the plural sec. 16H(1) can, and in my opinion should, be construed as follows:

``Where the Chief Commissioner is satisfied, having regard to the nature and degree of ownership or control of the businesses, the nature of the businesses and any other matters that he considers relevant, that businesses carried on by members of a group are carried on substantially independently of, and are not substantially connected with the carrying on of a business or businesses of another member or other members of that group, the Chief Commissioner may, by order in writing served on those first mentioned members, exclude them from that group.''

I have used the expression ``business or businesses'' in the alternative because companies may be grouped even though they do not carry on any business at all (sec. 16B).

In applying the provision of sec. 21(b) of the Interpretation Act 1897 to the provisions of sec. 16H I do not overlook what was said in
Blue Metal Industries Ltd. & Anor v. R.W. Dilley & Anor (1970) A.C. 827 at p. 848. But I find no contrary intention in the other related provisions of the Act here under consideration which would exclude the prima facie rule concerning words in the singular. I have already expressed the view that the result is to enlarge the ameliorating provisions directed at absurd or unjust operation of the various grouping provisions.

This conclusion renders it unnecessary to consider the alternative submission made by Mr Hill which relates to the point of time at which sec. 16H should be applied in relation to the operation of sec. 16E. That submission is summarised at pp. 10-11 of the transcript of the arguments.

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The parties agreed that, if the defendant had proceeded upon an erroneous construction of his powers under sec. 16H, the plaintiffs would be entitled to succeed. I therefore order that the objections of the plaintiffs for the year ended 30 June 1977-1984 inclusive be allowed. I remit the matters to the Chief Commissioner of Pay-roll Tax for him to exercise his discretion under sec. 16H(1) of the Pay-roll Tax Act 1971 according to law, and to assess any liability of the plaintiffs to such tax according to law. I order the defendant to pay the costs of the plaintiffs.


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