Revenue Laws Amendment (Assessment) Act 2000 (WA)

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Western Australia

Revenue Laws Amendment (Assessment) Act

2000

Western Australia

Revenue Laws Amendment (Assessment) Act

2000

CONTENTS

Part 1 — Preliminary

1.

Short title

2

2.

Commencement

2

Part 2 — Stamp Act 1921 amended

Division 1 — Preliminary and miscellaneous

3.

The Act amended

3

4.

Third Schedule amended

3

Division 2 — Corporate reconstructions

5.

Section 75J amended

3

6.

Section 75JB amended and transitional provision

3

7.

Section 75JBA inserted

6

75JBA.

Operation of claw-back — application for

pre-determination in certain cases

6

8.

Section 75JDA inserted and transitional provision

7

75JDA.

Exemption may be withheld in certain

cases

7

9.

Sections 75JE and 75JF amended

9

10.

Section 75JG amended

9

Division 3 — Power to reassess

11.

Section 31 amended

10

12.

Sections 31AA, 31AB and 31AC inserted

10

31AA.

Reassessment of duty

10

31AB.

Effect of reassessment

12

31AC.

Payment of reassessed duty

13

Revenue Laws Amendment (Assessment) Act 2000

Contents

13.

Section 32 amended

14

14.

Section 33 amended

15

15.

Section 39 amended

15

Division 4 — Exemption from duty on licensing

of modified motor vehicles

16.

Third Schedule amended

16

Part 3 — Land Tax Assessment

Act 1976 amended

17.

The Act amended

17

18.

Section 18A inserted

17

18A.

Certain public authorities to be treated as

owners

17

19.

Schedule amended

18

9A. (a)

Class of land

18

Western Australia

Revenue Laws Amendment (Assessment)

Act 2000

No. 29 of 2000

An Act to amend the —

Stamp Act 1921; and

Land Tax Assessment Act 1976,

and for related purposes.

[Assented to 6 July 2000]

The Parliament of Western Australia enacts as follows:

Revenue Laws Amendment (Assessment) Act 2000

Part 1

Preliminary

s. 1

Part 1 — Preliminary

1.             Short title

This Act may be cited as the Revenue Laws Amendment

(Assessment) Act 2000.

2.             Commencement

(1)

Subject to subsection (2) this Act comes into operation on the

day on which it receives the Royal Assent.

(2)

Part 3, other than section 19(2) is deemed to have come into

operation on 30 June 1995.

Revenue Laws Amendment (Assessment) Act 2000

Stamp Act 1921 amended

Part 2

Preliminary and miscellaneous

Division 1

s. 3

Part 2 — Stamp Act 1921 amended

Division 1 — Preliminary and miscellaneous

3.             The Act amended

The amendments in this Part are to the Stamp Act 1921*.

[* Reprinted as at 22 October 1999 .

For subsequent amendments see 1999 Index to Legislation of

Western Australia, Table 1, pp. 236-7.]

4.             Third Schedule amended

Item 2(7c) of the Third Schedule is amended by deleting

“section” and inserting instead —

and ”.

Division 2 — Corporate reconstructions

5.             Section 75J amended

Section 75J(2)(a)(ii) is amended by deleting “company” and

inserting instead —

“ body corporate ”.

6.             Section 75JB amended and transitional provision

(1)

Section 75JB(5) is repealed and the following subsections are

inserted instead —

(5)

If within 5 years after the execution of the instrument

or the date of the relevant acquisition A and B cease to

be associated then the claw-back applies.

(5a)

The claw-back under subsection (5) does not apply if A and B cease to be associated in circumstances where A has no assets or no assets other than cash or money in

an account at call or on deposit with any person or a

negotiable instrument.

Revenue Laws Amendment (Assessment) Act 2000

Part 2

Stamp Act 1921 amended

Division 2

Corporate reconstructions

s. 6

(5b)

If A is liquidated a reference in subsection (5a) to its

assets is a reference to them at the time of the

appointment of the liquidator and at all subsequent

times until they are distributed to the shareholders.

(5c)

In subsections (5c) to (5j) —

“controlling body” means —

(a)

in a case to which subsection (5e)(a) applies, a body corporate which, at the time of the execution of the instrument or the date of the relevant acquisition, owned and controlled the parent body;

(b)

in a case to which subsection (5e)(b) applies, a body corporate which, at the time the association referred to in subsection (5e)(b) arose, owned and controlled the parent body;

“own and control” a body corporate means to

beneficially own (directly or indirectly) at least

90% of the issued share capital of, and have

control (within the meaning of section 75J(2)(b))

over, the body corporate;

“parent body” means the other body corporate

referred to in subsection (5d) or, if there is more

than one of them, whichever of them did not, at the

relevant time or date mentioned in the definition of

“controlling body”, own and control any of the

others;

“qualifying period” has the same meaning as it has in

subsection (1)(d).

(5d)

An association is a “prescribed relationship” for the purposes of subsection (5e) if A and B are associated because another body corporate owns and controls each

of them.

Revenue Laws Amendment (Assessment) Act 2000

Stamp Act 1921 amended

Part 2

Corporate reconstructions

Division 2

s. 6

(5e)

For the purposes of subsection (5f), the “relevant

circumstances” have occurred if —

(a)

the association between A and B which satisfied the requirement of subsection (1)(c) was a prescribed relationship for the whole or a part of the qualifying period; or

(b)

the association between A and B which prevents the claw-back under subsection (5) from applying is a prescribed relationship.

(5f)

If the relevant circumstances have occurred and, on or

after 25 May 2000 and within 5 years after the

execution of the instrument or the date of the relevant

acquisition, the parent body —

(a)

ceases to beneficially own (directly or indirectly) at least 90% of the issued share capital of B; or

(b)

ceases to have control (within the meaning of section 75J(2)(b)) over B,

then —

(c)

the parent body and B shall notify the Commissioner in writing in a form approved by the Commissioner within one month after the relevant event; and

(d) the claw-back applies.

(5g)

Despite subsection (5f)(d), the Commissioner may, on

an application under this subsection, waive the

claw-back if —

(a)

a body corporate approved by the continues to own and control B; and

(b)

the Commissioner is satisfied that waiving the claw-back would not be inconsistent with the objects of this section.

Revenue Laws Amendment (Assessment) Act 2000

Part 2

Stamp Act 1921 amended

Division 2

Corporate reconstructions

s. 7

(5h)

The application shall be in writing in a form approved

by the Commissioner.

(5i)

The Commissioner may require the person making the

application to provide any information and evidence

that the Commissioner needs for the purposes of

subsection (5g).

(5j)

If the claw-back is waived under subsection (5g) —

(a)

subsection (5f) then applies as if references in it to the parent body were references to the body corporate approved under subsection (5g); and

(b)

a reference in this Part to subsection (5f)(c) is to be read as a reference to that provision as applied by paragraph (a).

”.

(2)

In the event of a cessation of ownership or control referred to in section 75JB(5f)(a) or (b) of the Stamp Act 1921 as inserted by subsection (1) taking place on or after 25 May 2000 and before this Act receives the Royal Assent, the notification required by section 75JB(5f)(c) of that Act is to be given within one month after this Act receives the Royal Assent.

7.             Section 75JBA inserted

After section 75JB the following section is inserted —

75JBA. Operation of claw-back — application for

pre-determination in certain cases

(1)

Terms used in this section have the same meanings as

they have in section 75JB.

(2)

If a cessation of ownership or control referred to in

section 75JB(5f)(a) or (b) is proposed or contemplated

in circumstances where a controlling body will

continue to own and control B, a person acting on

behalf of B, the parent body or the controlling body,

Revenue Laws Amendment (Assessment) Act 2000

Stamp Act 1921 amended

Part 2

Corporate reconstructions

Division 2

s. 8

may request the Commissioner to determine whether in

those circumstances the Commissioner would, under

section 75JB(5g), approve the controlling body and

waive the claw-back.

(3)

The request shall be in writing in a form approved by

the Commissioner.

(4)

The Commissioner may require the person making the

request to provide any information and evidence that

the Commissioner needs to make the determination.

(5)

If the Commissioner is given sufficient information to

do so the Commissioner shall make the requested

determination.

(6)

If the Commissioner determines that the controlling body would be approved and the claw-back waived then, on an application under section 75JB(5g), the Commissioner shall approve the controlling body and

waive the claw-back unless the Commissioner is of the

opinion that in relation to the request for a

determination there was not a full and true disclosure

of relevant information and evidence.

”.

8.             Section 75JDA inserted and transitional provision

(1)

After section 75JD the following section is inserted —

75JDA. Exemption may be withheld in certain cases

(1) In this section —

“duty avoidance arrangement” means an

arrangement —

(a)

avoiding or circumventing the operation of the provisions of this Part so far as they make the availability and continued effect of an exemption under section 75JB dependent

Revenue Laws Amendment (Assessment) Act 2000

Part 2

Stamp Act 1921 amended

Division 2

Corporate reconstructions

s. 8

on bodies corporate having been associated

for a particular period or remaining

associated for a particular period; or

(b)

having as its purpose, or one of its purposes, the reduction of duty that might otherwise become payable.

(2)

Without limiting section 75JC, the Commissioner may

determine under that section that an exemption under

section 75JB would not be granted in respect of an

instrument or a Part IIIBA statement if the

Commissioner considers that the instrument or

statement would, if executed or lodged, relate or be

likely to relate to a duty avoidance arrangement.

(3)

Even if on an application under section 75JD it is

shown to the satisfaction of the Commissioner that

section 75JB applies, the Commissioner may refuse to

grant an exemption under section 75JB(3) in respect of

an instrument or a Part IIIBA statement if the

Commissioner considers that the instrument or

statement relates or is likely to relate to a duty

avoidance arrangement.

(4)

Despite subsection (3), if the Commissioner is required under section 75JC(5) to grant an exemption in respect of an instrument or a Part IIIBA statement, the

exemption is to be granted even if the Commissioner considers that the instrument or statement relates or is likely to relate to a duty avoidance arrangement.

”.

(2)

In subsections (3) and (4) —

“transitional period” means the period beginning on

25 October 1999 and ending when subsection (1) comes

into operation.

Revenue Laws Amendment (Assessment) Act 2000

Stamp Act 1921 amended

Part 2

Corporate reconstructions

Division 2

s. 9

(3)

If an exemption under section 75JB of the Stamp Act 1921 has

been granted during the transitional period and the

Commissioner is of the opinion that it would not have

been granted if subsection (1) had come into operation on

25 October 1999, the claw-back under Part IIIBAAA of that Act

applies.

(4)

Section 75JDA(4) of the Stamp Act 1921 does not apply to a

requirement under section 75JC(5) of that Act if the

determination under section 75JC was made during the

transitional period.

9.             Sections 75JE and 75JF amended

Sections 75JE(1)(b) and 75JF(1)(b) are amended by inserting

after “75JB(4)” —

“ or (5f)(c) ”.

10.           Section 75JG amended

(1)

Section 75JG(1) and (2) are amended by inserting after

“75JB(4)” —

“ or (5f)(c) ”.

(2)

Section 75JG(3) is amended as follows:

(a)

by deleting “75JC or an application under section” and inserting instead —

75JBA or 75JC or an application under

section 75JB(5g) or

”;

Revenue Laws Amendment (Assessment) Act 2000

Part 2

Stamp Act 1921 amended

Division 3

Power to reassess

s. 11

(b)

exemption has been made under section” and inserting

in paragraph (b), by deleting “an application for an “

a request has been made under section 75JBA

or an application has been made under

section 75JB(5g) or

”.

Division 3 — Power to reassess

11.           Section 31 amended

Section 31(4) is amended by deleting “An” and inserting

instead —

“ Subject to section 31AA, an ”.

12.           Sections 31AA, 31AB and 31AC inserted

After section 31 the following sections are inserted —

31AA. Reassessment of duty

(1)

If, on or after the day on which the Revenue Laws

Amendment (Assessment) Act 2000 receives the Royal

Assent, the Commissioner has expressed an opinion

under section 31(1) in relation to an instrument, the

Commissioner —

(a)

must if directed to do so by a court determining an appeal under section 33 or giving an opinion under section 34; and

(b)

subject to subsection (2), may of the Commissioner’s own volition,

reconsider whether or not the instrument is chargeable

with duty and, if so, the amount of duty with which it is

chargeable.

Revenue Laws Amendment (Assessment) Act 2000

Stamp Act 1921 amended

Part 2

Power to reassess

Division 3

s. 12

(2)

However if the Commissioner’s previous opinion in

relation to the instrument was based on —

(a)

an interpretation of the applicable law; or

(b) the Commissioner’s practice,

that was generally applied to instruments of that kind

when that opinion was expressed, then the

Commissioner cannot reconsider the instrument under

subsection (1)(b) on the ground that the interpretation

or practice is or was erroneous.

(3) The Commissioner —

(a)

must reconsider an instrument under subsection (1)(a); and

(b)

may reconsider an instrument under subsection (1)(b),

even if it has already been reconsidered under

subsection (1).

(4)

If the Commissioner reconsiders an instrument under

subsection (1) and is of the opinion —

(a)

if the Commissioner was previously of the opinion that the instrument was not chargeable with duty, that the instrument is chargeable with duty; or

(b)

that the amount of duty with which the instrument is chargeable is more than the amount that was previously assessed as being chargeable,

the Commissioner is to —

(c)

issue a reassessment of duty in respect of the instrument; and

(d)

endorse on the instrument the amount of duty with which it is chargeable.

Revenue Laws Amendment (Assessment) Act 2000

Part 2

Stamp Act 1921 amended

Division 3

Power to reassess

s. 12

(5)

Subject to subsection (6), the Commissioner may only

issue a reassessment within 5 years of the date of the

original assessment issued in relation to the instrument.

(6)

Even if more than 5 years have elapsed since the

original assessment was issued the Commissioner —

(a)

must issue a reassessment if directed to do so by a court; and

(b)

may issue a reassessment if the Commissioner is of the opinion that —

(i)      there has been an evasion of tax; or

(ii)      any previous assessment was issued on the basis of false or misleading information.

(7)

An instrument on which the duty has been reassessed by the Commissioner under this section shall not, if it is unstamped or insufficiently stamped, be stamped

otherwise than in accordance with the reassessment of

duty issued under this section in respect of that

instrument.

31AB.

Effect of reassessment

(1)

A reassessment supersedes the previous assessment

issued in relation to the instrument.

(2)

A reassessment does not invalidate proceedings for the recovery of duty but an appropriate adjustment may be made to the amount to be recovered in the proceedings to accord with the reassessment.

(3)

If an objection to an assessment is lodged and, before

determination of the proceedings on the objection, a

reassessment is issued, the proceedings may be

continued against the reassessment to the extent that it

is liable to the same objection or to an objection that is

the same or similar in substance.

Revenue Laws Amendment (Assessment) Act 2000

Stamp Act 1921 amended

Part 2

Power to reassess

Division 3

s. 12

31AC.

Payment of reassessed duty

(1)

In this section —

“payment period” means the period, or the extended

period, referred to in section 20(3).

(2)

If a reassessment is issued after the full amount of the

duty chargeable under the original assessment has been

paid in relation to the instrument, then the difference

between that amount and the reassessed amount of duty

must be paid within —

(a) the payment period; or

(b)

the period of one month after the day on which the reassessment is issued,

whichever ends later.

(3)

If the full amount required to be paid under

subsection (2) is not paid within the period required

under that subsection, or within any period allowed

under section 34C(2), the instrument shall, in addition

to being charged with that amount, be charged with a

fine equal to 20% of that amount or a fine of $2,

whichever is greater.

(4)

Any fine chargeable under subsection (3) shall be in

addition to, and not in substitution for, any fine

chargeable under section 20.

(5)

Any fine charged under subsection (3) shall be denoted

on the instrument concerned by a stamp.

(6)

The Commissioner may remit wholly or in part any

fine chargeable under subsection (3).

(7) If —

(a)

no duty, or less than the full amount of duty, has been paid in relation to the instrument; and

Revenue Laws Amendment (Assessment) Act 2000

Part 2

Stamp Act 1921 amended

Division 3

Power to reassess

s. 13

(b)

the reassessment is issued not less than one month before the expiry of the payment period,

then the references in section 20(3) to the amount of

duty payable are to be read as references to the

reassessed amount of duty less any amount of duty

already paid.

(8) If —

(a)

no duty, or less than the full amount of duty, has been paid in relation to the instrument; and

(b)

the reassessment is issued after, or within one month before, the expiry of the payment period —

then, in section 20(3) —

(c)

the references to the amount of duty payable are to be read as references to the reassessed amount of duty less any amount of duty already

paid; and

(d)

the reference to the payment period is to be read as a reference to the period ending one month after the day on which the reassessment

is issued.

”.

13.           Section 32 amended

(1)

Section 32(5) is amended by inserting after “20” —

“ or 31AC ”.

(2)

Section 32(6) is amended by inserting after “shall include” —

“ a reassessment issued under section 31AA and ”.

Revenue Laws Amendment (Assessment) Act 2000

Stamp Act 1921 amended

Part 2

Power to reassess

Division 3

s. 14

14.           Section 33 amended

Section 33(4) is amended by deleting “, and order the

Commissioner to refund the amount of any excess of duty

which may have been paid and the amount of any excess of any

fine charged under section 20.” and inserting instead —

or 31AC, and order the Commissioner —

(a)

if the Court determines that the instrument has been charged with excess duty, to refund the amount of any of that excess of duty which may have been paid and the amount of any excess of any fine charged under section 20 or 31AC; or

(b)

if the Court determines that the instrument has been charged with insufficient duty, to reassess the instrument under section 31AA.

”.

15.           Section 39 amended

(1)

Section 39(1a)(b) is amended by inserting after “20(3)” —

or the full amount required to be paid under

section 31AC(2) is not paid within the period

required under section 31AC(2), or the

extended period referred to in section 31AC(3)

”.

(2)

Section 39(1a)(d) is amended by deleting “section 20(2) or (3)

or 20(2) and (3)” and inserting instead —

one or more of section 20(2), section 20(3) and

section 31AC(3)

”.

Revenue Laws Amendment (Assessment) Act 2000

Part 2

Stamp Act 1921 amended

Division 4

Exemption from duty on licensing of modified motor vehicles

s.

16

Division 4 — Exemption from duty on licensing of modified

motor vehicles

16.           Third Schedule amended

After item 9(4) of the Third Schedule the following subitems

are inserted —

(5)

A licence issued to a person for a motor vehicle —

(a)

that was modified and that was, before the issue of the licence, last licensed in that person’s name under —

(i)      the RTA;

(ii)      a law of any other country corresponding to the RTA; or

(iii)      a corresponding State law;

or

(b)

that was part of a motor vehicle that was modified and that was, before the issue of the licence, last licensed in that person’s name under —

(i)      the RTA;

(ii)      a law of any other country corresponding to the RTA; or

(iii)      a corresponding State law.

(6)

The exemption in subitem (5) applies whether or not a

motor vehicle that results from the modification needs to

meet a standard or requirement before it can be licensed that

is different to the one that the original vehicle had to meet.

”.

Revenue Laws Amendment (Assessment) Act 2000

Land Tax Assessment Act 1976 amended

Part 3

s. 17

Part 3 — Land Tax Assessment Act 1976 amended

17.           The Act amended

The amendments in this Part are to the Land Tax Assessment

Act 1976*.

[* Reprinted as at 30 July 1996.

For subsequent amendments see 1999 Index to Legislation of

Western Australia, Table 1, p. 135.]

18.           Section 18A inserted

After section 18 the following section is inserted —

18A.

Certain public authorities to be treated as owners

If — (a) a body that —

(i)      is established by an Act; and

(ii)      is liable to assessment and taxation under this Act in relation to any land that it owns, or would be so liable if it owned land;

or

(b)

a body that is excluded from the definition of “public statutory authority” by regulations made for the purposes of that definition,

has land vested in it, other than as owner, by or under

an Act, that body is to be treated as if it were the owner

of that land for the purposes of this Act.

”.

Revenue Laws Amendment (Assessment) Act 2000

Part 3

Land Tax Assessment Act 1976 amended

s. 19

19.           Schedule amended

(1)

After clause 1(b) of Part I of the Schedule the following

paragraphs are inserted —

(c)

Qualification for certain public authorities

If the owner of any land referred to in paragraph (a) includes

a body referred to in section 18A, that land is not exempt

land. However, no-one referred to in paragraph (a) (other

than the body, where relevant) is liable for assessment and

taxation under this Act in respect of that land.

(d)

Paragraph (c) prevails over paragraph (b)

If paragraphs (b) and (c) would otherwise make different

persons liable for assessment and taxation in relation to

particular land, only the person liable under paragraph (c) is

so liable.

”.

(2)

After clause 9 of Part I of the Schedule the following clause is

inserted —

9A. (a)

Class of land

If, in relation to land and to a year of assessment —

(i)      the owner is not, or none of the owners are, using the land solely or principally as his or her or their sole or principal place of residence at midnight on 30 June immediately preceding that year because of

a requirement that the land be vacant pursuant to a

mortgagee’s right to sell the land; and

(ii)      an exemption under clause 9, 10 or 11 of this Part would have applied to that year of assessment in respect of the land but for that requirement,

an exemption applies to that year of assessment in respect of

the land to the extent one would have if the owner, or an

owner, were using the land solely or principally as his or her

Revenue Laws Amendment (Assessment) Act 2000

Land Tax Assessment Act 1976 amended

Part 3

s. 19

sole or principal place of residence at midnight on 30 June

immediately preceding that year.

(b)

Qualifications

The exemption in paragraph (a) does not apply if —

(i)      the owner, or an owner, is entitled in that year of assessment to an exemption under clause 9, 10 or 11 of this Part in respect of any other land; or

(ii)      any person derives rent or other income from the land during the period when the land was required to be vacant.

The exemption in paragraph (a) applies for one year of

assessment only, in relation to the owner or owners and the

land.

(c)

Application

This clause applies to the year of assessment commencing

on 1 July 2000 and for each subsequent year of assessment.

”.

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