On 4 November 2014 the High Court completed the hearing of the Commissioner’s appeal of the Full Federal Court’s decision in Commissioner of Taxation v MBI Properties Pty Ltd [2013] FCAFC 112. The appeal was part herd on 11 September 2014.

The transcript of the hearing on 11 September 2014 can be accessed here.

The transcript of the hearing on 4 November 2014 can be accessed here.

The fundamental issue put by the Commissioner in the appeal is that the decision of the Full Federal Court in South Steyne that there is no supply by the purchaser of a reversion made to the tenant sitting at the time of purchase was wrong and that the Court below was wrong to follow it.

The documents filed by the parties are as follows:

• Commissioner’s submissions – my post discussing the submissions can be accessed here
• Commissioner’s chronology
• Taxpayer’s submissions – my post discussing the submissions can be accessed here
• Commissioner’s reply