Ferguson and Eidson (Child support)
[2025] ARTA 247
•9 January 2025
Ferguson and Eidson (Child support) [2025] ARTA 247 (9 January 2025)
Applicant/s: Ms Ferguson
Respondent: Child Support Registrar
Other Parties: Mr Eidson
Tribunal Number: 2024/BC028085
Tribunal: Member I Sheck
Place:Melbourne
Date:9 January 2025
Decision:The decision under review is varied so that the departure determination is as follows:
·For the period 25 September 2023 to 31 December 2023, the annual rate of child support is set at $3,934. The payer is Ms Ferguson;
·For the period 1 January 2024 to 4 March 2024, the annual rate of child support is set at $4,226. The payer is Ms Ferguson;
·For the period 5 March 2024 to 13 June 2024, the annual rate of child support payable by either party is set at $0;
·For the period 14 June 2024 to 31 December 2024, the annual rate of child support payable by Mr Eidson to Ms Ferguson is to be reduced by $4,888;
·For the period 1 January 2025 to 31 December 2025, the annual rate of child support payable by Mr Eidson to Ms Ferguson is to be reduced by $5,220;
·For the period 1 January 2026 to 31 December 2026, the annual rate of child support payable by Mr Eidson to Ms Ferguson is to be reduced by $5,671.
CATCHWORDS
CHILD SUPPORT – departure from the administrative assessment – adjusted taxable incomes and care percentages – costs of educating child – congenital condition and learning difficulties – distances between parents’ homes and possible schools – father paying for private schooling – mother’s change in employment, study and start of own business, with fluctuating income – father’s steady increase in income – decision under review varied
Names used in all published decisions are pseudonyms. Any references appearing in square brackets indicate that information has been omitted from this decision and replaced with generic information pursuant to subsection 16(2AB) of the Child Support (Registration and Collection) Act 1988.
Statement of Reasons
BACKGROUND
Ms Ferguson and Mr Eidson are the separated parents of [the child], born 4 July 2016. The records of Services Australia – Child Support (Child Support) indicate that the child support assessment was registered on 11 December 2019 and Child Support has been responsible for the collection of the liability since then. As at 19 April 2022 the annual rate of child support payable by Mr Eidson under the administrative assessment was $2,449, based on the adjusted taxable incomes of the parties for the 2020-21 year and care percentages of 50% each for Ms Ferguson and Mr Eidson.
Mr Eidson applied to Child Support for a departure from the administrative assessment on 19 April 2022 on the basis that, in the special circumstances of the case, the assessment was unfair due to the costs of educating the child in a particular manner (otherwise referred to as “Change of assessment Reason 3”). On 20 July 2022, Child Support decided to depart from the administrative assessment and made a determination setting the rate of child support payable by Mr Eidson at $0 for the period 19 April 2022 to 31 January 2024.
On 25 September 2023 Mr Eidson made a further application for departure from the administrative assessment due to the costs of [the child]’s education. Mr Eidson sought a change in the rate of child support such that the annual amount payable by Ms Ferguson to himself be set at $4,775. On 7 February 2024 a Child Support officer made a determination ending the earlier departure determination with effect from 24 September 2023 and adjusting Ms Ferguson’s adjusted taxable income and the rates payable such that the annual rate of child support payable by Ms Ferguson to Mr Eidson was “around $4,660” for the period 25 September 2023 to 31 December 2024.[1]
[1] Hearing papers, page 240
On 6 March 2024 Ms Ferguson objected to the decision and provided further evidence, including that she had lost her job on 5 March 2024. An objections officer of Child Support reviewed and set aside the original decision on 17 May 2024. The objections officer set a variety of child support rates over the period 25 September 2023 to 31 December 2024 and additionally set Ms Ferguson’s adjusted taxable income at $0 for the period 6 March 2024 to 31 May 2024.
On 15 June 2024, Ms Ferguson lodged an application to the Administrative Appeals Tribunal (AAT) for review of the objections officer’s decision. From 14 October 2024, the AAT became the Administrative Review Tribunal (the Tribunal). Under the transitional provisions in the Administrative Review Tribunal (Consequential and Transitional Provisions No. 1) Act 2024 (the Transitional Act), applications for review to the AAT that were not finalised before 14 October 2024 are taken to be an application for review to the Tribunal. The Transitional Act gives the Tribunal the authority to continue and finalise any aspect of the review not already completed by the AAT. This decision and statement of reasons is made by the Tribunal.
On 11 July 2024 and 20 December 2024, the AAT received documents numbered 1 to 469 from Child Support. A Directions Hearing was held on 28 November 2024 and the parties were directed to provide various documents. Further documents numbered A1 to A62 and B1 to B28 were submitted by Ms Ferguson and Mr Eidson respectively pursuant to the directions of 28 November 2024 and were provided to both parties. On 6 January 2025, the Tribunal conducted a hearing at which Ms Ferguson and Mr Eidson gave evidence by MS Teams video.
CONSIDERATION
The legislative framework and issues for the Tribunal to determine
The rate of child support payable by a liable parent is usually based on an administrative assessment under Part 5 of the Child Support (Assessment) Act 1989 (the Act). This involves the application of a statutory formula, which takes into account factors such as the number of children, the age of each child, the level of care provided and the income of each parent. The income used in the calculation has a number of components making up the adjusted taxable income, which is worked out using section 43 of the Act. The general approach is that the Child Support Registrar will utilise a parent’s adjusted taxable income as assessed by the Australian Taxation Office for the last relevant year of income. Where there is a reduction in a parent’s income, for instance if they lose their employment, the administrative assessment allows for the rate to be based on their estimated income for the current financial year.
The liable parent or a carer may apply for a determination departing from the administrative assessment under Part 6A of the Act. Section 98C establishes a three-step process to be satisfied prior to a departure determination being made: that there is a ground for a departure from the administrative assessment; that it is just and equitable to depart; and that it is otherwise proper to do so. Once satisfied as to these three issues, the Tribunal may make one of the determinations prescribed in section 98S of the Act.
Reason 3 – Education or training of children in the manner expected by the parents
Subparagraph 117(2)(b)(ii) of the Act provides that a ground for departure from an administrative assessment exists if, in the special circumstances of the case, the costs of maintaining the child or children are significantly affected because the child is being cared for, educated or trained in the manner that was expected by his or her parents. In this case Mr Eidson applied for a change in the assessment due to the costs of [the child]’s education at [School 1], where he commenced at prep level in 2022.
The term “special circumstances” is not defined in the Act. In Gyselman and Gyselman [1991] FamCA 93 (Gyselman) the Full Court of the Family Court indicated that for there to be special circumstances, the facts of the case must establish something which is special or out of the ordinary. Likewise, in Philippe and Philippe (1978) FLC 90-433 the Court held that “special circumstances” are “facts peculiar to the particular case which set it apart from other cases”.
Ms Ferguson told the Tribunal that prior to [the child] starting school she and Mr Eidson lived fairly close together but Mr Eidson subsequently moved to the Gold Coast. When they were discussing [the child]’s schooling they were both open to private school education but Ms Ferguson thought that maybe [the child] could attend public schooling for primary school. They considered a number of schools, both private and public, that were equidistant from their homes. Of the schools they considered, [School 1] was the most expensive. Mr Eidson told the Tribunal that he and Ms Ferguson did consider a number of schools but due to [the child]’s learning difficulties[2] they considered that [School 1] would be the best. Mr Eidson pointed out that in the consent orders of 10 March 2022, which were signed by both parties, it was agreed “That the child shall attend upon [School 1] for schooling.”[3]
[2] [The child] suffers from [a] congenital condition that can lead to global developmental delay
[3] Hearing papers, page B28, point 26
In terms of whether [the child] is being educated in the manner expected by the parents, Ms Ferguson and Mr Eidson are in agreement that private school education was discussed and in view of [the child]’s medical condition the Tribunal considered it likely that this was a factor in the decision that was made regarding the type of education. Overall, the Tribunal is satisfied that private education is the manner of schooling that was selected by the parents at the time that [the child] commenced school. In her evidence to Child Support as well as the Tribunal, Ms Ferguson has raised a number of factors such as [School 1] being more expensive than comparable private schools such as [School 2], as well as the considerable distance between her home and [School 1]. While the Tribunal accepts that these are relevant issues for Ms Ferguson, this is not the test that is required when determining whether this ground for departure has been met.
Turning to the costs of [the child]’s education, the Tribunal notes that costs due to excursions, uniforms, booklists and so on are common to both private and public education and are already considered as costs of the children in the calculation of the child support payable under the administrative assessment. The additional costs for private school are generally calculated as comprising tuition fees plus compulsory capital levy. The total payable by way of these components is as follows:
· $2,126 per term or $8,504 in 2022;
· $2,298 per term or $9,192 in 2023;
· $2,444 per term or $9,776 in 2024; and
· $2,610 per term or $10,440 in 2025.
As noted above, the annual rate of child support payable by Mr Eidson prior to the first change of assessment application was $2,449. Although the rate would have varied somewhat due to changes in the adjusted taxable incomes of the parents, it is clear that the additional amounts payable to [School 1] by way of education expenses significantly affect the cost of maintaining [the child]. The Tribunal consequently finds that there are special circumstances in this application which establish a ground for departure under subparagraph 117(2)(b)(ii) of the Act in relation to [the child]’s education. While Ms Ferguson has stated that she cannot afford to contribute to [the child]’s schooling, this is a consideration to be taken into account in determining whether it is just and equitable to depart from the administrative assessment.
Is it fair or ‘just and equitable’ to make a particular departure determination?
As the Tribunal is satisfied that there is a ground to depart from the administrative assessment of child support, the next step is to consider whether it is fair as regards the parents and the children to make a particular determination in accordance with sub‑subparagraph 98C(1)(b)(ii)(A) of the Act. This in turn requires the Tribunal to have regard to a range of factors, including but not limited to those set out in subsections 117(4) and (6) to (8) of the Act, such as the needs of the children, the parents’ assets, liabilities, income and commitments and any hardship that would be caused by departing or not departing from the formula. The Tribunal does not propose to explore every matter in detail but will discuss those it regards as pertinent to this application (Gyselman).
The needs of the child
Section 3 of the Act makes it clear that the parents of a child have the primary duty to maintain the child, and that this duty has priority over all commitments of the parents other than commitments necessary for self-support or the support of another person the parent has a duty to maintain (Ashcroft and Ashcroft (SSAT Appeal) [2008] FMCAfam 1250). In this case, Mr Eidson and Ms Ferguson have the primary duty to financially support [the child] and contributing to his costs should take priority over all other costs other than their “necessary” costs of self-support.
In determining the proper needs of the child, subsection 117(6) of the Act requires the Tribunal to have regard to the manner in which the parents expected the child to be cared for, educated and trained as well as a consideration of any special needs of the child. The Tribunal has already discussed the costs of [the child]’s education above. In terms of whether [the child] has special needs, either by way of medical conditions or additional costs for training due to special skills or talents, he suffers from [a congenital condition]. Ms Ferguson told the Tribunal that [the child] has undergone surgeries to remove benign growths in his brain. He sees his specialist twice yearly and takes medication. [The child] has developmental delay and is improving greatly, particularly over the last year. He has weekly speech therapy, fortnightly occupational therapy and counselling. Ms Ferguson told the Tribunal that the cost of these therapies are covered by [the child]’s NDIS plan, however they are likely to reduce the frequency of counselling sessions this year so that the funding limit is not exceeded. On her Statement of Financial Circumstances Ms Ferguson has listed out of pocket costs of $12 a week for [the child]’s “medical, dental and optical” expenses. Mr Eidson has listed his expenses for this item as $5 a week and the Tribunal is satisfied that these amounts are accurate. Both Ms Ferguson and Mr Eidson receive carer allowance for [the child], which would cover any residual out of pocket expenses.
The Tribunal concludes that other than the school fees, [the child]’s costs are consistent with the normal costs for a child of his age.
The earning capacity, income, property and financial resources and commitments of each parent
Ms Ferguson
There have been a number of changes to Ms Ferguson’s employment and financial situation recently. Ms Ferguson told the Tribunal that she worked for [Employer 1] for many years and in September 2023 left [Employer 1] to take up a better paying position with [Employer 2]. Prior to this Ms Ferguson’s adjusted taxable income had been around $80,000 since the 2020-21 year. The Tribunal notes that the original decision maker assessed Ms Ferguson’s income from her new employment as $127,140 per annum, however Ms Ferguson has made the point that this is purely her gross income and does not include any work-related deductions. The Tribunal agrees. It can be seen from Ms Ferguson’s 2023-24 year income tax return that she claimed deductions of $11,804 over the year. The Tribunal considered that an assessable income of $120,000 would be a more appropriate reflection of her income during the period of her employment with [Employer 2].
Ms Ferguson was dismissed from her position at [Employer 2] with effect from 5 March 2024. She contended that the main contributing factor to this was the amount of travel that she had to undertake from her home to her work in [Suburb] (north of her home) then to [School 1] (south of her home), which adversely impacted her working hours. The Tribunal accepts that this is the case. Following her dismissal Ms Ferguson completed a [Subject] course and her income tax return indicates that she received jobseeker payment. Ms Ferguson registered her own business “[Business name]” in mid-2024 and has been running this business since October 2024. Ms Ferguson told the Tribunal that she presently receives carer payment from Centrelink. She has completed one [business] deal since commencing the business and hopes to ramp up the business now that the Christmas/New Year break is over. The Tribunal put to Ms Ferguson that she had estimated her 2024-25 year taxable income to Child Support as $23,255 and Ms Ferguson responded that she hoped it would be more than that. Ms Ferguson advised that the reason she decided to start her own business was that her time was more flexible; also she works from home, which has resulted in a significant reduction in her travel times. As a result of the travelling that she was undertaking, she developed a disc bulge and sciatica for which she received various treatments including acupuncture and physiotherapy. Ms Ferguson stated that she could no longer afford medical treatment for this.
In her Statement of Financial Circumstances Ms Ferguson lists her income as $95,000 per annum, this comprising ~$1,000 a week from her business as well as $572.20 per week in carer payment (which is a tax-free payment that forms part of a person’s adjusted taxable income per section 43 of the Act). As this is the maximum carer payment rate for a single person[4] (before application of the income test) it would appear that this amount will reduce once Ms Ferguson’s business starts to generate income.
[4] From “A guide to Australian Government payments” at >
It is then necessary to consider the commitment of each parent to support himself or herself, and any other child or person that they have a duty to maintain. The Tribunal finds that Ms Ferguson does not have a legal duty to support any other children or dependent adults. Mr Eidson has a duty to support his other son [Master A] and pays child support accordingly.
Turning to Ms Ferguson’s commitments, she lists loan and credit card repayments of $180 a week. Ms Ferguson lists her household expenses as $1,669 per week ($86,788 annual), however this includes $284 a week for council rates. Ms Ferguson explained that this amount includes arrears that she had incurred and will be paid off soon. The Tribunal noted that Ms Ferguson’s largest expense is her home mortgage of $716 a week. It appears from the household expenses table that Ms Ferguson’s partner [Mr B] does not contribute at all to the costs of accommodation including utilities. Ms Ferguson told the Tribunal that [Mr B] is a self-employed [occupation 1] and runs his own business from home. She lists his income as $1,600 a week. While it is of course not [Mr B]’s responsibility to financially support [the child], when determining whether the making of a particular determination would cause hardship to Ms Ferguson the Tribunal must consider the overall financial situation of the household and the proportion of household expenditure incurred by her. There is nothing to indicate that Ms Ferguson has a legal liability to support [Mr B] and the Tribunal has found she does not. The Tribunal is not satisfied that Ms Ferguson’s financial commitments are as set out in her Statement of Financial Circumstances.
Mr Eidson
Mr Eidson is [an occupation 2] with [Employer 1] and his adjusted taxable income shows a steady increase each year. In the 2023-24 year Mr Eidson’s gross income from employment was $161,053 and his adjusted taxable income (taxable income plus net investment loss, per section 43 of the Act) is $155,348. Mr Eidson no longer has a net investment loss as he sold his investment property when he relocated to be closer to [the child]’s school. Ms Ferguson asserted that Mr Eidson had a novated lease which reduces his taxable income but this is not supported by the documents before the Tribunal and the Tribunal finds he does not. The Tribunal concludes that Mr Eidson’s adjusted taxable income is an appropriate reflection of his available income and financial resources.
Turning to Mr Eidson’s financial commitments, these are set out in his Statement of Financial Circumstances. Mr Eidson’s child support liability for [Master A] is reflected in the administrative assessment. He has a [car] loan with stated repayments of $127 a week but it appears from the loan statement that he is paying more than the minimum amount required. Mr Eidson lists his household expenses as $3,160 a week, the main component of which is the mortgage of $1,135 a week. Mr Eidson has listed his own expenses as $1,182 a week and [the child]’s expenses as $950 a week. The remainder of the expenses are incurred by Mr Eidson’s partner [Ms C], [an occupation 3]. Mr Eidson lists [Ms C]’s income as $1,364 a week and her expenses include appropriate proportions of all household line items. As discussed above, [the child]’s additional expenses due to his private education are around $200 a week at present. This leaves some $750 a week for his other expenses incurred by Mr Eidson. The costs of the child under the administrative assessment are presently calculated as $16,940 or $326 a week. This is the total as would be incurred by both households. The Tribunal concludes that Mr Eidson’s outlay on [the child] includes an amount of discretionary spending, as is indeed reflected in the household expenses table.
What is the determination that is to be made?
The central point to this application is whether Ms Ferguson should contribute towards [the child]’s private schooling expenses, which have been entirely met by Mr Eidson since [the child] commenced school in 2022. Mr Eidson is of the view that Ms Ferguson should pay 50% of the school fees as they each have [the child] in their care for 50% of the time. Mr Eidson has also made the point that he considers it unjust for him to pay for the whole of the school fees as well as paying child support to Ms Ferguson directly. The point must, however, be made that if the rate payable under the administrative assessment is more than “Ms Ferguson’s’ half” of the school fees then if the rate payable is reduced by half of the relevant education costs there would still be an amount to be paid to Ms Ferguson by Mr Eidson. Ms Ferguson has made the point that as her income is lower than Mr Eidson’s, she should be required to contribute a lower proportion of the education costs. Further to this, Ms Ferguson submitted that her contributions should be reduced by her additional costs of taking [the child] to school and back, as she lives much further from the school than Mr Eidson does. The problem with adopting this approach is that there have been significant fluctuations in Ms Ferguson’s income, such that an appropriate proportion would be difficult to establish.
Mr Eidson told the Tribunal that prior to [the child] starting school in 2022 he was attending childcare. The costs of childcare were around the same as the private school fees. Each of the parents paid the childcare fees for the weeks that [the child] was in their care. The Tribunal considered this to be a valid point and concludes that it is just and equitable for Ms Ferguson to be liable for 50% of [the child]’s ongoing costs of education. In terms of how this liability would affect Ms Ferguson going forward, the Tribunal was unable to come to a definite finding regarding Ms Ferguson’s income or financial commitments, however concludes that making such a contribution will not cause hardship to Ms Ferguson, [the child] or her household as she develops her business.
Turning then to the past assessment, Mr Eidson initially applied for a change of assessment in April 2022 and a determination was made setting the rate of child support payable by him at $0 from 19 April 2022 to 31 January 2024. The annual rate otherwise payable by him under the administrative assessment was $2,449 to July 2022 and $1,803 from 1 August 2022 onward. This meant that Ms Ferguson was actually contributing some 25% of the school fees in 2022 and 20% in 2023. In considering whether it would be appropriate to increase Ms Ferguson’s liability for a period prior to 25 September 2023, the Tribunal was not of the view that it was. Mr Eidson stated that he was unaware that he could request a change to the assessment such that Ms Ferguson would be the payer of child support to him. While the Tribunal accepts that this is the case, careful reading of the original decision maker’s decision of 20 July 2022 reveals that the original decision maker considered whether it was just and equitable to make Ms Ferguson the payer and concluded it was not. It was open to Mr Eidson to object to this decision and he did not do so. Ms Ferguson was consequently entitled to make financial decisions on the basis of the assessment that was in place. The Tribunal is not of the view that in this situation a retrospective reassessment of the rate would be just or equitable.
Mr Eidson lodged the second departure application on 25 September 2023. There had been a change in circumstances as Ms Ferguson had secured new employment. At that time, had the administrative assessment still been in place, Mr Eidson would be liable to pay $3,014 to Ms Ferguson on the basis of their 2022-23 adjusted taxable incomes as assessed by the Australian Taxation Office of $86,164 (Ms Ferguson) and $143,644 (Mr Eidson).[5] Ms Ferguson had, however, changed employment and consequently increased her income. Her income from the new position after relevant work-related expenses was around $120,000 per annum. Applying the child support formula to this would result in a rate of $662 payable by Mr Eidson to Ms Ferguson. Changing the annual rate of child support payable by Ms Ferguson to Mr Eidson to $3,934 to 31 December 2023 and $4,226 from 1 January 2024 would mean that Ms Ferguson has been responsible for payment of half of the school fees in this period. The Tribunal notes that these amounts are a little less than the rates determined by the objections officer as deductions have been applied.
[5] Hearing papers, pages 386 and 399
Ms Ferguson then became unemployed from 5 March 2024 and her income tax return confirms that she was receiving jobseeker payment at some point. In her objection letter dated 6 March 2024[6] Ms Ferguson has outlined a number of outstanding debts, including 3 payday loans. The Tribunal is of the view that Ms Ferguson had no capacity to contribute to [the child]’s education costs at this time. This means that the child support rate payable by her should revert to $0 from 5 March 2024. The Tribunal has considered Mr Eidson’s income and his household expenses and liabilities and concludes that Ms Ferguson’s lack of contribution to the costs of education from 5 March 2024 would not cause Mr Eidson undue hardship.
[6] Hearing papers, page 277
On 14 June 2024 Ms Ferguson estimated her income for the 2023-24 year would be $23,255. This estimate was accepted by Child Support and applied to the assessment. A further estimate of $23,255 was also made for the 2024-25 year and applied to the assessment with effect from 1 July 2024. The effect of these estimates of income was to increase the annual rate calculated under the administrative assessment to $6,520 from 14 June 2024 and $7,092 from 1 September 2024 (when a new child support period started). These amounts would be payable by Mr Eidson to Ms Ferguson. The Tribunal therefore concludes that it is just and equitable to reduce the rate of child support payable by Mr Eidson from 14 June 2024 to factor in Ms Ferguson’s liability to pay 50% of the school fees.
In terms of an end date to the determination, the decision made by the objections officer has already ended. Both parties were in favour of extending the departure determination so as to obviate the need for another application in the near future and the Tribunal agrees that would be a sensible outcome. In order to continue a determination that reduces the amount of child support payable by Mr Eidson by half of the education costs, it would be necessary for the assessed annual amount (as calculated under the administrative assessment) to exceed around $5,000. This is the case during the 2025 calendar year (until the end of the current child support period). In the 2024-25 year Ms Ferguson has had a period of unemployment and is now starting up her own business. The Tribunal considers it likely that her adjusted taxable income will not be such in the 2024-25 year that would result in an overall annual rate of less than $5,000 in 2026. [the child] will enter Grade 4 in 2026. Assuming an increase in [School 1] fees of say 6%, which has been the case over the last couple of years, the total costs of education will be ($2,335 + $340) x 1.06 = $2,835.50 per term: $11,342 in total or $5,671 each.
The Tribunal considered whether it should continue the departure determination to the end of the 2027 year, however, given the unpredictability of Ms Ferguson’s potential business income once her business has become established, the Tribunal did not think it was appropriate to do so.
Is it otherwise proper to make a particular departure determination?
The third step is to consider whether it would be otherwise proper to make a particular departure determination in accordance with sub-subparagraph 98C(1)(b)(ii)(B) of the Act. Subsection 117(5) of the Act sets out the matters that must be considered when deciding whether it would be “otherwise proper” to make a departure determination. The relevant matters under this step relate to whether the child support payee receives family tax benefit from Centrelink. A decision to depart from the administrative assessment which results in an increase in the rate of child support will reduce the impact on the public purse as the amount of child support payable reduces the amount of family tax benefit received. In this case the Tribunal’s determination will result in a reduction in the child support liability from the rate payable under the administrative assessment and a consequent increase in Ms Ferguson’s family tax benefit entitlement from September 2023 to March 2024 and January 2025 onward. Notwithstanding this, the Tribunal considers that it is in any event otherwise proper to make the particular determination to more appropriately reflect the responsibilities of both parents to provide financially for [the child].
DECISION
The decision under review is varied so that the departure determination is as follows:
For the period 25 September 2023 to 31 December 2023, the annual rate of child support is set at $3,934. The payer is Ms Ferguson;
For the period 1 January 2024 to 4 March 2024, the annual rate of child support is set at $4,226. The payer is Ms Ferguson;
For the period 5 March 2024 to 13 June 2024, the annual rate of child support payable by either party is set at $0;
For the period 14 June 2024 to 31 December 2024, the annual rate of child support payable by Mr Eidson to Ms Ferguson is to be reduced by $4,888;
For the period 1 January 2025 to 31 December 2025, the annual rate of child support payable by Mr Eidson to Ms Ferguson is to be reduced by $5,220;
For the period 1 January 2026 to 31 December 2026, the annual rate of child support payable by Mr Eidson to Ms Ferguson is to be reduced by $5,671.
Date(s) of hearing: Monday, 6 January 2025
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