Royal Siam Pavilion Thai Spa and Cafe (Migration)

Royal Siam Pavilion Thai Spa and Cafe (Migration) [2019] AATA 1287 (10 April 2019)
DECISION RECORD
DIVISION:Migration & Refugee Division
APPLICANT:  Royal Siam Pavilion Thai Spa and Cafe
CASE NUMBER:  1507796
DIBP REFERENCE(S):  OPF2014/1810
MEMBER:Karen Synon
DATE:10 April 2019
PLACE OF DECISION:  Melbourne
DECISION:The Tribunal sets aside the decision under review and substitutes a decision not to take one or more of the actions specified in s.140M of the Migration Act 1958.
Statement made on 10 April 2019 at 11:07am

CATCHWORDS
MIGRATION – cancellation – sponsorship approval – compliance with sponsorship obligations – keep records – payment of wages in cash – independent verification – unclear or incomplete information on Department’s website – combination of signed payslips, BAS statements, taxation records, business summaries and superannuation payment records – micro-business – credible witness – decision under review set aside
LEGISLATION
Migration Act 1958 (Cth), ss 140L, 140M
Migration Regulations 1994 (Cth), rr 2.82, 2.89
STATEMENT OF DECISION AND REASONS
APPLICATION FOR REVIEW

This is an application for review of a decision made by a delegate of the Minister for Immigration to take an action under s.140M of the Migration Act 1958 (the Act) in relation to the applicant’s sponsorship.
The applicant was approved as a standard business sponsor on sponsor on 18 October 2012. On 7 May 2015, the delegate decided to bar the sponsor from sponsoring more people for Temporary Work (skilled) (Subclass 457) visas for 12 months, under s.140M on the basis that the sponsor has failed its obligation to keep records: r.2.82.
Background
On 3 April 2014 the sponsor was advised, via letter, that the department had commenced monitoring the business and requested records and information.
On 16 July 2014, a delegate of the Minister for Immigration issued a Notice of Intention to Take Action (NOITA) to the applicant. The NOITA sets out the details of the circumstances in relation to which action was being considered and provided the applicant with the opportunity to respond or comment. The issues were identified as:
Regulation 2.79 – Obligation to ensure equivalent terms and conditions of employment; and
Regulation 2.82 – Obligation to keep records.
On 30 July 2014 the review applicant provided a submission in response to the NOITA.
On 7 May 2015, the delegate decided to bar the sponsor, Royal Siam Pavilion Thai Spa & Café (‘Royal Siam’) for a period for 12 months, with immediate effect, from sponsoring more people for Temporary Work (skilled) (Subclass 457) visas. In doing so the delegate did not find that the sponsor had breached obligation 2.79: Obligation to ensure equivalent terms and conditions of employment; but was satisfied that the sponsor had not met regulation 2.82: Obligation to keep records.
The applicant applied for review of the primary decision on 8 June 2016 and provided a copy of the Department’s decision to the Tribunal.
This case was originally constituted to another member on 5 October 2016 however when it was unable to be finalised by that member, on 23 January 2019 it was reconstituted.
Mr Mariusz Paks, on behalf of the review applicant, Royal Siam Pavilion Thai Spa & Café appeared before the Tribunal on 14 March 2019 to give evidence and present arguments.
The applicant was represented in relation to the review by its registered migration agent. He did not attend the hearing.
At the hearing on 14 March 2019 the Tribunal was informed that Mr Paks had closed the business trading as Royal Siam Pavilion Thai Spa & Café on 1 September 2015 and divested himself of his interest in the actively trading business by transferring this to Mr Sarit Benjawilaikul. However Mr Paks has maintained the registered business name ‘Royal Siam Pavilion Thai Spa & Café and therefore, with this continuing legal entity, the Tribunal finds that it has jurisdiction continue with this review application.
Asked why he decided to continue with the review when the substantive business to which it relates has closed, Mr Paks explained that he wants to protect his integrity which he believes was questioned in the bar decision. He explained that he came to know Mr Sarit Benjawilaikul when he was a massage therapist working in Sunbury and that, due to a falling out with his sister’s family, Mr Benjawilaikul was left without employment. At the time Mr Paks was working as a consulting engineer in Melbourne. He later worked as a lecturer in Engineering at Victoria University. Mr Paks effectively set up the business in order to provide employment to Mr Benjawilaikul and based this business in Bendigo. It was managed on a daily basis by Mr Benjawilaikul with oversight from Mr Paks who did not work in the business as he was employed in Melbourne and lived in Sunbury. The second 457 employee, Ms Praphawarini Deekate was known to Mr Benjawilaikul and he recommended her for this position.
The Tribunal found Mr Paks to be a most genuine and credible witness. His evidence was that this was the first time he had run a business or employed anyone. The Tribunal was left in no doubt that his intention and desire to comply with the obligations of sponsorship were sincere.
For the following reasons, the Tribunal has decided to set aside the decision under review and substitute a decision not to take one or more of the actions specified in s.140M.
CONSIDERATION OF CLAIMS AND EVIDENCE
Sections 140K, 140L and 140M of the Act provide for the imposition of sanctions on approved sponsors in certain circumstances.
Under s.140M, if prescribed circumstances exist, the Minister (and the Tribunal on review) may take one or more of the following actions:
·cancelling the sponsorship approval in relation to a class to which the sponsor belongs;
·cancelling the sponsorship approval for all classes to which the sponsor belongs;
·barring the sponsor for a specified period from sponsoring more people under the terms of any existing approval; and
·barring the sponsor for a specified period from making future applications for sponsorship approval in relation to one or more classes of sponsor.
For these purposes, the circumstances are prescribed in r.2.89 - r.2.94B and include circumstances in which the Minister, or Tribunal on review, is satisfied there has been: a failure to satisfy a sponsorship obligation; provision of false or misleading information; sponsorship application or variation criteria no longer met; a contravention of the law; unapproved changes to a program; a failure to pay additional security; a failure to comply with certain terms of an agreement; or a failure to pay medical and hospital expenses.
Where a prescribed circumstance has been found to exist, the regulations prescribe criteria that must be taken into account when determining what action, if any, to take: r.2.89 – r.2.94B. These criteria, as they relevantly apply to the circumstances of this case are set out in the attachment to this decision.
Does a circumstance for the taking of an action exist?
In the present case, the delegate found that that the review applicant breached its obligation to keep records: r.2.82.
Failure to satisfy a sponsorship obligation: r.2.89
The Minister may take one or more of the actions in s.140M if satisfied the sponsor has failed to satisfy a sponsorship obligation referred to in Division 2.19 of the Regulations: r.2.89(2).
Under s.140L(1)(a)(i) and r.2.89, a circumstance in which the Minister may take one or more of the cancelling / barring actions is that the Minister is satisfied that the sponsor has failed to satisfy a sponsorship obligation. All sponsors are, from 14 September 2009, subject to a series of sponsorship obligations, although not all obligations apply to all types of sponsors. The sponsorship obligations are listed in r.2.78 - 2.87C. Relevant to this review is regulation 2.82 - Obligation to keep records.
Specifically the nature of this obligation under r.2.82 requires current and former approved sponsors to keep records of their compliance with their other obligations. Sponsors are required to keep records that are specified for the particular class of sponsor in r.2.82[1] as well as records of a kind specified by instrument.[2] This obligation requires that:
·the records must be in a reproducible format;[3]
·the records are kept for a particular period (see below for the particular period being no more than 5 years);[4] and
·either, the records must be kept in a manner specified by written instrument,[5] or in a manner that is capable of being verified by an independent person for records relating to:
-payment of return travel costs to sponsored persons (see below);[6]
-other money paid to, applied or dealt with on a primary sponsored person’s behalf or as directed by them (see below);[7] and
-compliance with requirements relating to training specified by instrument (see below).[8]
[1] Included as an attachment to this decision.
[2] r.2.82(2)(aa).
[3] r.2.82(2)(b).
[4] r.2.82(2)(d) when read with r.2.82(4), (5) and (6).
[5] r.2.82(2)(c)(i). There is currently no instrument for r.2.82(2)(c)(i).
[6] r.2.82(2)(c)(ii) and r.2.82(3)(a)(iii). Regulation 2.82(2)(c)(ii) was amended by SLI 2013, No.146 in relation to a person who is or was a standard business sponsor on or after 1 July 2013.
[7] r.2.82(2)(c)(ii) and r.2.82(3)(e)(i) and (ii). Regulation 2.82(2)(c)(ii) was amended by SLI 2013, No.146 in relation to a person who is or was a standard business sponsor on or after 1 July 2013.
[8] r.2.82(2)(c)(ii) and r.2.82(3)(g), amended by SLI 2013, No.146 in relation to a person who is or was a standard business sponsor on or after 1 July 2013.
This obligation on a current or former standard business sponsor is to keep the following records from the day of sponsorship approval until two years after the first day on which the employer ceases to be an approved sponsor and there is no sponsored person in relation to the employer ,[9] for a primary sponsored person, earning below a specified threshold[10]
a.a record of the money paid to them, and money applied or dealt with in any way on their behalf or as directed by them;[11]
b.a record of non-monetary benefits provided to them, including their agreed value and the time at which, or period over which, they were provided;[12] and
c.if there is an equivalent worker in the person’s workplace, a record of the terms and conditions applicable to that worker, including the period they applied;[13]
[9] r.2.82(2)(d) when read with r.2.82(4) and (6).
[10] r.2.82(3)(e). The threshold is specified under r.2.79(1) and (1A). See Obligation to ensure equivalent terms and conditions of employment – r.2.79 above for further detail. The instrument which specifies the income threshold for the purposes of r.2.79(1A) can be found in the MRD Legal Services Register of Instruments – Business Visas under the ‘TSMIT’ tab.
[11] r.2.82(3)(e)(i)-(ii).
[12] r.2.82(3)(e)(iii).
[13] r.2.82(3)(e)(iv).
A sponsor is also required to keep a copy of the written contract of employment under which the primary sponsored person is employed.
In making this decision the Tribunal is concerned only in relation to the period of time that the two employees were the holders of 457 visas and working in Australia. These periods are:
·Mr Sarit Benjawilaikul 5 November 2012 to 30 August 2013;[14] and
·Ms Praphawarini Deekate 1 March 2014 to 11 May 2014.
[14] The Tribunal notes that on 30 August 2013 Mr Sarit Benjawilaikul was granted permanent residency.
In determining this review the Tribunal notes that the department’s website provides some, but not clear or complete, information on what constitutes the obligation to keep records. The Department of Home Affairs website[15] states:
[15] < accessed 14 March 2019.
You must keep records to show your compliance with your sponsorship obligations. All records must be kept in a reproducible format and some[16] must be capable of verification by an independent person. In addition to records kept under other Australian government, and state or territory laws, also keep records of:
[16] Tribunal’s emphasis.
owritten requests for payment of travel costs for the employee or their family, including when the request was received
ohow and when you paid the travel costs, how much you paid, and who you paid it to
oany event you need to report to us, including the date and method of notification and where the notification was provided
otasks performed by the employee in relation to the nominated occupation and where the tasks were performed
oearnings paid to the sponsored visa holder (unless the sponsored visa holder earns AUD250,000 or more)
omoney applied or dealt with in any way on behalf of, or as directed by, the employee (unless the sponsored visa holder earns AUD250,000 or more)
onon-monetary benefits provided to the employee. Record the agreed value and the time at which, or the period over which, those benefits were provided (unless the sponsored visa holder earns AUD250,000 or more)
oif there is an equivalent worker in your workplace, the terms and conditions of the equivalent worker, including the period over which the terms and conditions apply (unless the sponsored visa holder earns AUD250,000 or more)
othe written contract of employment you engage each employee under
ohow you are complying with the training obligations if you were lawfully operating a business in Australia when we approved your standard business sponsorship or the terms of your approval as a standard business sponsor were varied
othe records you need to keep as party to a work agreement, if applicable
oThis obligation starts the day we approve your sponsorship or the nominee starts work with you.
oThis obligation ends two years after:
o your sponsorship or the work agreement ends and
o you no longer employ a sponsored visa holder
The review applicant in his NOITTA response to the Department on 30 July 2014 highlights that the department does not state which records needed to be independently verifiable per se as it says some not all. The review applicant asserted in this response that it had in fact kept records and these were comprised of:
·Employee payslips which were signed by each employee, so were ‘receipts’ for individual payments.
·The two sponsored persons were both interviewed by the monitoring officers, and they have confirmed their salary levels and payments are being made. This is independent verification.
·BAS statements also provide a means of independent verification of salary payments.
The review applicant relevantly submitted that:
·To minimise paperwork, it had opted to make monthly salary payments with an opportunity for staff to be paid cash advances mid-month.
·The tax office allows salary payments to be made in cash.
·The departmental website states that the department exchanges information with ATO and FWO. As the ATO has information regarding payments to its workers, through BAS and tax returns, this can be seen as independent.
·All staff members had specifically requested payments made by cash.
·The nomination application provides three methods of payment to a nominee, and cash in an allowable option.
·The sponsor argued that if paying by cash was a breach of Regulation 2.82, it would not be listed as an option of payment in the nomination application.
The delegate acknowledged these arguments and the sponsor’s position that it complied with its obligations, but stated “the sponsor’s claims cannot be accepted in this instance”.
In a submission to the Tribunal the review applicant relevantly submitted:
We consider that we had an adequate system in place which allowed for an independent verification of payments having been made (which is the DIBP requirement).
a.We maintained appropriate documentation and systems to prove payments made.
b.These systems are in line with systems considered to be adequate by other government departments and used widely across Australia, including the Tax Office.
c.Furthermore, the alternative system recommended by the Department of payments into an employee’s account does not offer any better safeguards than the system we have introduced.
d.There were good and justifiable reasons for us to introduce a cash payment system.
Even if the Department disagreed with our assessment of system adequacy, the penalty imposed is very harsh.
a.In relation to Ms Deekate, at an early opportunity and long before the decision was made we offered to the Department that payments could be made via deposits to her account, and indeed one payment was made into her account prior to her permanent departure from Australia for family reasons. We received no response to this offer between the date of our letter (30 July 2014) and the Department’s decision (7 May 2015), and the matter was not addressed in the Department’s decision.
b.Even if there was a breach, it was only short term (approximately months – the actual duration of employment of Ms Deekate) and primarily was a result of the time taken to make her bank account operational.
c.The allegations of any wrongdoing by us, contained in the decision, result from the Department misrepresenting the figures produced to them.
The review applicant throughout the course of the department process and before the Tribunal steadfastly refuted the assertion that cash payments paid as salary or wages are not able to be independently verified highlighting that the alternative system preferred by the Department is no better safeguard to employees in the hands of unscrupulous employees. It was explained that a cash payment system was implemented because as a micro-business, employing no more than 4 employees at any one time, it accepted cash payments from clients. Most business payments to suppliers were made in cash (with only rent, utility bills and insurance paid by bank transfers). Making cash payments, including salaries, were the easiest and cheapest way of conducting business. Mr Paks noted that in both nomination applications he indicated that he would be paying salaries in cash for the 457 nominees and at no time was this questioned.
Mr Paks, on behalf of the review applicant, has consistently stated that he believed that the combination of signed payslips, BAS statements, taxation records (such as individual year end of year PAYG summaries) and business summaries, in addition to superannuation payment records provide adequate independent verification of the salary amounts paid.
At the conclusion of the hearing Mr Paks agreed to provide:
·Hesta superannuation records of payments made for Mr Sarot Benjawilaikul for the period he was employed on a 457 visa being 5 November 2012 to 30 August 2013 inclusive
·Hesta superannuation records of payments made for Ms Praphawarini Deekate for the period she was employed on a 457 visa being 1 March 2014 to 11 May 2014 inclusive.
·Copies of PAYG statements provided by the Australian Taxation Office for Mr Sarot Benjawilaikul for the financial years ending 30 June 2012 and 30 June 2013.
·Copies of PAYG statements provided by the Australian Taxation Office for Ms Praphawarini Deekate for the financial year ending 30 June 2014.
·A copy of your spreadsheet listing all staff and payments for the relevant period that Mr Sarot Benjawilaikul and Ms Praphawarini Deekate were employed on 457 visas.
·A statutory declaration from Mr Sarit Benjawilaikul.

Following the hearing these documents were provided. In his statutory declaring Mr Sarit Benjawilaikul relevantly declared:
I would like to confirm that when I was on a 457 visa between 5 November 2012 and 30 August 2013, I was always paid the correct amount and on time, as show on the payslips previously submitted to the Immigration Department.
All payment have been made in cash and I had an option of requesting advance payment, also recorded on the pay slips. I was very happy with this arrangement as it was convenient for me.
I was being reimbursed for any expenses related to the operation of the business if I paid for them myself in cash.
The Tribunal has reviewed the spreadsheet provided by Hesta Superannuation which clearly records all the contributions made by the review applicant on behalf of Mr Sarit Benjawilakul and Ms Praphawarini Deekate (and another employee who was not a 457 visa holder) for the period November 2012 until May 2014 which covers the entire period in question (being 5 November 2012 to 30 August 2013 for Mr Benjawalakul and 1 March 2014 to 11 May 2014 for Ms Deekate). The Tribunal has also been provided with: the relevant PAYG payment summaries for both Mr Benjawalakul and Ms Deekate; Business Activity Statements which record ‘total salary, wages and other payments; and a detailed spread sheet complied contemporaneously by Mr Paks recording all salary payments, tax withheld and superannuation paid during the relevant periods.
After considered the arguments and evidence of Mr Paks and the documentation provided and having had the benefit of taking oral evidence from Mr Paks who provided clear and considered explanations of the veracity and reliability of the records kept, the Tribunal is satisfied that these records, considered in totality, are Regulation 2.82 compliant and specifically are capable of being: in a reproducible format; kept for the relevant period being, in this case, until 2 years after there is no sponsored person in relation to the employer; and verified by an independent person. Relevantly the Tribunal is satisfied that these records contain a record of all the money paid to the two 457 visa holders.
In making this finding the Tribunal also notes that as a result of the Department’s concerns the sponsor commenced paying Ms Deekate via electronic transfer and has provided evidence to the Tribunal of this. It accepts Mr Pak’s evidence that while Ms Deekate was paid in cash in March 2014 (indeed she had only opened a bank account later that month and it was not fully operational at the time of her March salary payment), in April 2014 she was paid directly to her bank account. Ms Deekate took compassionate leave in May and returned to Thailand.
Disclosure of the 375A Certificate
During the hearing the Tribunal advised the review applicant that there is some information on the department file which is subject to a certificate issued under s.375A of the Act. The Tribunal advised that it had formed the view that this certificate is valid and provided a copy of it to the review applicant.
The Tribunal advised that the gist of this information is covered in the Certificate and in essence the monitoring of his business commenced as a result of a site visit in relation to the lodgement of a further nomination for another massage therapist. The Tribunal advised that it did not intend to rely on any of the information contained in these documents in its decision as it does not consider these folios contained any relevant adverse information that was not also contained in either or both the NOTTA and/or or the primary decision. Invited to comment on this Mr Paks declined to do so.
Action to be taken
As the Tribunal finds that none of the circumstances for s.140L(1)(a) exist, it follows that the power to take an action under s.140M does not arise.
DECISION
The Tribunal sets aside the decision under review and substitutes a decision not to take one or more of the actions specified in s.140M of the Migration Act 1958.
Karen Synon

Member
ATTACHMENT – Extracts from the Migration Regulations 1994
MIGRATION REGULATIONS 1994 - REG 2.82
Obligation to keep records
(1) This regulation applies to a person who is or was an approved sponsor.
(2) The person must keep records:
(a) of a kind:
(i) if the person is a standard business sponsor--specified in subregulation (3); or
(ii) if the person is a party to a work agreement--specified in subregulations (3) and (3A); or
(iii) if the person is a temporary activities sponsor, a temporary work sponsor or a professional development sponsor--specified in paragraphs (3)(a) and (b); and
(aa) of a kind specified by the Minister in an instrument in writing (if any) made for this subparagraph; and
(b) in a reproducible format; and
(c) either:
(i) in the manner specified by the Minister in an instrument in writing (if any) made for this subparagraph; or
(ii) if the record is a record mentioned in subparagraph (3)(a)(iii), (3)(e)(i), (3)(e)(ii) or paragraph (3)(g)--in a manner that is capable of being verified by an independent person; and
(d) for the period specified in subregulation (4), (5) or (6).
(3) For paragraph (2)(a), the records are:
(a) if the obligation mentioned in regulation 2.80 applies to the person:
(i) a record of the written request by the primary sponsored person or secondary sponsored person for the payment of return travel costs; and
(ii) a record of when the written request for the payment of return travel costs was received by the person; and
(iii) a record of how the person complied with the request to pay return travel costs, including:
(A) the costs paid; and
(B) who the costs were paid for; and
(C) the date of the payment of the costs; and
(b) if the obligation mentioned in regulation 2.84 applies to the person:
(i) a record of a notification to Immigration of an event specified in regulation 2.84 for the person; and
(ii) a record of the particulars of the notification of the event, including:
(A) the date on which the person notified Immigration of the event; and
(B) the method by which the notification was provided; and
(C) where the notification was provided; and
(c) if:
(i) the primary sponsored person holds a Subclass 457 (Temporary Work (Skilled)) visa or a Subclass 482 (Temporary Skill Shortage) visa; or
(ii) the last substantive visa held by the primary sponsored person was a Subclass 457 (Temporary Work (Skilled)) visa or a Subclass 482 (Temporary Skill Shortage) visa;
a record of the tasks performed by the primary sponsored person in relation to work undertaken in relation to the nominated occupation; and
(d) a record of the location or locations at which the tasks mentioned in paragraph (c) were performed; and
(e) if the obligation mentioned in regulation 2.79 applies to the person:
(i) a record of the money paid to the primary sponsored person; and
(ii) a record of the money applied or dealt with in any way on the primary sponsored person's behalf or as the primary sponsored person directed; and
(iii) a record of the non-monetary benefits provided to the primary sponsored person, including the agreed value and the time at which, or the period over which, those benefits were provided; and
(iv) if there is an equivalent worker or workers in the person's workplace--a record of the terms and conditions that apply, or did apply, to an equivalent worker or workers, including the period over which the terms and conditions applied; and
(f) a copy of the written contract of employment under which the primary sponsored person is employed; and
(g) if the person was approved as a standard business sponsor before 12 August 2018 and was lawfully operating a business in Australia at the time of:
(i) the person's approval as a standard business sponsor; or
(ii) the approval of a variation to the person's approval as a standard business sponsor;
all records showing that the person has complied with requirements relating to training specified by the Minister in an instrument in force before 12 August 2018 under subregulation 2.87B(2) (as in force before 12 August 2018); and
(h) records to substantiate the annual turnover (within the meaning of the Migration (Skilling Australians Fund) Charges Regulations 2018 ) for nominations in relation to which the person is liable for nomination training contribution charge.
(3A) For subparagraph (2)(a)(ii), the records are the records specified in the work agreement as records that must be kept.
(4) If the person is or was approved as a sponsor in a class of sponsor under subsection 140E(1) of the Act, the obligation mentioned in subregulation (2):
(a) starts to apply on the day on which the person is approved as a sponsor in a class of sponsor under subsection 140E(1) of the Act; and
(b) ends 2 years after the first day on which each of the following occurs concurrently:
(i) the person ceases to be an approved sponsor;
(ii) there is no primary sponsored person or secondary sponsored person in relation to the person.
…
2.89   Failure to satisfy sponsorship obligation
…
(3) For paragraph 140L(1)(b) of the Act, the criteria that the Minister must take into account in determining what action (if any) to take under section 140M of the Act in relation to the circumstance mentioned in subregulation (2) are:
(a)     the past and present conduct of the person in relation to Immigration; and
(b)    the number of occasions on which the person has failed to satisfy the sponsorship obligation; and
(c)     the nature and severity of the circumstances relating to the failure to satisfy the sponsorship obligation, including the period of time over which the failure has occurred; and
(d)    the period of time over which the person has been an approved sponsor; and
(e)     whether, and the extent to which, the failure to satisfy the sponsorship obligation has had a direct or indirect impact on another person; and
(f)     whether, and the extent to which, the failure to satisfy the sponsorship obligation was intentional, reckless or inadvertent; and
(g)    whether, and the extent to which, the person has cooperated with Immigration, including whether the person informed Immigration of the failure; and
(h)    the steps (if any) the person has taken to rectify the failure to satisfy the sponsorship obligation, including whether the steps were taken at the request of Immigration or otherwise; and
(i)    the processes (if any) the person has implemented to ensure future compliance with the sponsorship obligation; and
(j)    the number of other sponsorship obligations that the person has failed to satisfy, and the number of occasions on which the person has failed to satisfy other sponsorship obligations; and
(k)     any other relevant factors.
…

[2019] AATA 1287

10 April 2019

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Immigration

Administrative Law

Legal Concepts

Judicial Review

Procedural Fairness

Jurisdiction

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Appeal