CASE 3/2016
Members:SE Frost DP
Tribunal:
Administrative Appeals Tribunal, Sydney
MEDIA NEUTRAL CITATION:
[2016] AATA 348
SE Frost (Deputy President)
1. In the 2008 income year the applicant's family trust sold an office building to an arm's length purchaser for about $72 million. The building had cost roughly $30 million to construct. The family trust treated the gain on sale, of about $40 million, as a capital gain. Because the building had been owned for over 12 months a 50 per cent discount on the capital gain was applied.
2.
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After the application of the 50 per cent discount, the gain was distributed via intermediate beneficiaries to people including the applicant. The applicant declared the gain in his tax return for 2008 and paid tax on it.3. The Commissioner considered that the gain on sale of the building was a revenue gain and should have been returned as ordinary income, without the application of the 50 per cent discount. The Commissioner amended the applicant's assessment for the 2008 year and also applied an administrative penalty of 50 per cent.
4. The parties now agree that the distribution from the family trust through an intermediate trust was wrong. The intermediate trust had no entitlement to a distribution from the family trust, and instead the distribution from the family trust should have flowed directly to the applicant. But it also turns out that the applicant is entitled to only one-sixth of the distribution from the family trust, not the 78 per cent that was originally attributed to him. It follows that the amended assessment is excessive, no matter whether the gain is treated as a capital gain or a revenue gain. The question that divides the parties is: by how much is the assessment excessive?
5. The applicant objected against the amended assessment but the objection was disallowed. The matter is now before the Tribunal as a review of the Commissioner's objection decision.
THE ISSUE FOR DETERMINATION
6. The only issue is whether the sale of the building in question gave rise to a capital gain or a revenue gain.
THE BACKGROUND FACTS
7. The broad background facts are set out in the affidavits of the applicant, Ivan Domazet, and his son Jure Domazet, and for the most part are not in dispute. I find them to be as follows[1]
8. Ivan is the founder of a successful property building, development and investment group of companies called the Doma Group. From its beginnings in 1974 as a residential home building business, the Group has become one of the largest multi-unit and commercial office development and construction companies and private hoteliers in the Australian Capital Territory.
9. Ivan migrated to Australia in 1964 and settled in Canberra soon afterwards. After a few years working as a glazier and then as a painter, he started employment as a builder. After a few years he started undertaking building projects on his own.
10. In around 1969, he started buying land and building residential houses for sale as house and land packages.
11. In 1975 he incorporated a company, Jure Investments Pty Ltd (Investments), which became the trustee of the Domazet Family Trust. Investments is a member of the Doma Group.
12. From the early 1980s, the Doma Group started to undertake multi-unit residential building projects. Generally speaking, the Group would purchase vacant land and build multi-unit residential developments on the land.
13. Sometimes the properties were sold more or less immediately upon completion of the development, and sometimes they were retained as longer-term investments. Sometimes some of the units in a development were sold and some of them were kept for longer periods[2]
14. The Doma Group's residential development activities continued throughout the 1980s and 1990s, but that was not all that it did.
15. In 1985 the Group purchased a commercial accommodation property known as Canberra Educational Tours Accommodation Centre. Initially that operation was expanded through the development of a 142-room hotel catering to students, sporting groups, low-cost tourists and corporates, with associated dining and conference facilities. That part of the expansion was completed in 1987, but then further work was done in 1994 and 1995 to result in a 209-room hotel with additional dining and conference facilities. The hotel became known as Hotel Heritage, and it was sold in 2007.
16.
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In addition, in the 1980s and 1990s the Doma Group had some commercial property investments. These were a half-share in a commercial office building in Braddon and, from 1995, a small office building in the same suburb, a warehouse in Hume and two small commercial buildings in Phillip.17. Jure joined the Doma Group in 1998 and is now its managing director. He came to the Group after working at St George Bank in a commercial finance role, and then as a solicitor at Clayton Utz, where he worked in the finance team, gaining experience in commercial lending, finance and structuring.
18. By 1999, and after consultation with his father, Jure decided to start progressively reducing the Doma Group's residential property portfolio and increasing its commercial property portfolio. Over the next two years the Doma Group sold its interests in a number of its apartment developments. Soon after that some of the smaller commercial investments, including those in Phillip and Hume, were also sold.
THE PURCHASE OF THE SIRIUS BUILDING AND THE WODEN CARPARK
19. In early 1999 the Doma Group was the successful tenderer for the purchase of an office building and a carpark in the Woden Town Centre in Canberra. The office building was known as the Sirius Building. It had been constructed in 1968. It was between three and four storeys high and had a gross floor area of 7,372 m2;. In 1999 it was subject to a lease to the Commonwealth agency, IP Australia. That lease ran until 2002.
20. Across the road from the Sirius Building was a two level concrete car park, known as the Woden carpark, which had space for around 210 cars. It had been built in 1969. The top floor of the Woden carpark was available for public parking and the bottom level was licensed for use by Commonwealth employees working in nearby offices.
21. The Sirius Building and the Woden carpark were offered for sale, as a package, by the Commonwealth through its agent Colliers Jardine. Mr Paul Powderly, an agent with Colliers, had a pre-existing relationship with the Doma Group. Mr Powderly told Jure that the building and the carpark were on the market and indicated to Jure that he thought the package would be an ideal purchase for the Group. His thinking was that it was well located in the Woden Town Centre, it was leased to a Commonwealth tenant until 2002 and, since there were no alternative buildings in the area, there was a strong likelihood that the tenant would enter into a further lease at the expiry of the current one. Mr Powderly believed that the Sirius Building and Woden carpark would provide a reliable stream of rental income for the Doma Group with Colliers managing the property on behalf of the Group with minimal management issues for a few years[4]
22. Jure gave evidence[5]
THE LANDSCAPE CHANGES
23. Soon after the purchase of the building and the carpark, a difficulty emerged. Neither the building nor the carpark had been built in accordance with the ACT Building Code and neither of them had a Certificate of Occupancy, as the Commonwealth did not have to comply with the Building Code when it built the buildings. This had been known prior to the purchase and did not create a problem so long as the Commonwealth either owned the properties or was the sole occupier of them. Therefore, the fact that the Sirius Building had not been built in accordance with the Building Code was not an issue for the Doma Group because the Commonwealth was and remained the tenant of the whole building. However, if a private owner such as the Doma Group were to make the Woden carpark available for public parking or for parking to persons other than the Commonwealth, it was required to comply with the ACT Building Code.
24. In due course the Commonwealth extended its lease for the Sirius Building to 2007, but indicated that it no longer required any parking in the Woden carpark. There were no other Commonwealth tenants in the Woden Town Centre requiring any direct leasing of car spaces in the Woden carpark either. While there
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may have been a market to license the carpark for use by private individuals or corporations, that was not legally allowed. As a result, the undercover portion of the carpark, representing half of its car spaces, had to be closed. The remaining half could continue to be made available for use, but the closure of the undercover portion removed the bulk of the income-generating potential of the site.REDEVELOPMENT CONSIDERED
25. The Doma Group started investigating other potential uses of the Woden carpark site. It considered upgrading the construction of the carpark to ensure it complied with the Building Code but the cost was thought prohibitive. The Group decided not to undertake the work.
26. A few development proposals were considered in the next two years but for various reasons none of them proceeded.
27. One of the difficulties in the redevelopment of the Woden carpark was that it was in a precinct of the Woden Town Centre that required not only the retention of the current car parking capacity, but also the provision of an additional 2.5 car parks per 100 m2 of gross floor area in the event that the property was redeveloped. That requirement may be contrasted with other precincts within the Woden Town Centre, including the site directly across the road, which required only 1 further car park per 100 m2 of gross floor area. According to Jure, this inhibited the preparation of redevelopment proposals for the Woden carpark site as the construction of basement car parking was not commercially viable in the Woden Town Centre.
28. In August 2002 the Doma Group was approached by Bovis Lend Lease (BLL), which had become aware of a foreshadowed request for proposals (RFP) by the Commonwealth for the provision of office accommodation in Woden. BLL proposed that the Doma Group retain BLL to design, project manage and construct a 10,000 m2 office building for the Doma Group on the Woden carpark site.
29. In late 2002 the Department of Health and Ageing (DoHA) issued an RFP for the provision of 11,000 to 14,000 m2 of office space in the Woden Town Centre. The Doma Group made two responses to DoHA's RFP. First, in December 2002, it proposed the construction of an 11,000 to 14,000 m2 office building on the Woden carpark site which was to be wholly leased to DoHA. This proposal involved the Doma Group constructing, owning and letting the building after construction. Secondly, in January 2003, the Doma Group lodged with DoHA another proposal for the construction of an office building on the site of the Woden carpark, but with BLL as the project manager, designer and constructor of a 15,000 m2 building. This proposal envisaged a 10 to 15 year lease of the building to DoHA by the Doma Group with an option to renew for a further five years.
30. DoHA did not proceed with the RFP. Nevertheless, the Doma Group continued to pursue redevelopment opportunities for the Woden carpark site.
31. In 2003 a new draft Woden Town Centre Master Plan foreshadowed a change to the car parking requirements for a redevelopment of the Woden carpark. The new draft Master Plan reduced the number of car parks required and also allowed taller buildings to be built on the site than previously. The new Master Plan was finalised in April 2004.
32. In February 2004, no doubt expecting imminent approval of the new Master Plan, the Doma Group lodged a Development Application (DA) with the ACT Government for the Woden carpark, proposing the construction of an eight storey office building with provision for 16,364 m² of office accommodation. The proposal envisaged that the building would be leased by one or more Commonwealth Departments and was known as the 'Glasshouse'. The DA for the Glasshouse was approved by the ACT Government in May 2005.
CONSTRUCTION OF THE GLASSHOUSE
33. In early 2005 the Doma Group demolished the Woden carpark and commenced excavation for the Glasshouse development.
34. At the time construction commenced there was no pre-commitment from prospective tenants. Jure acknowledged that this involved some risk to the Group, but he said he was confident, based on his knowledge of the commercial real estate market in Canberra at
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that time and the growing demand by Commonwealth departments for office accommodation, that the Group would be successful in obtaining tenants for the Glasshouse[6]35. Indeed, on 19 October that year, Investments entered into an agreement for lease with the Civil Aviation Safety Authority (CASA) for four floors of the Glasshouse for 15 years. On the following day, 20 October, Jure on behalf of the Group wrote to St George Bank requesting construction finance. In that letter he said:
On completion, the Phillip property could be sold, refinanced or the construction facility could be converted to an FDA with the Bank with the asset to provide core security. This is subject to its effect on the lending limits of the Bank.
36. However, Jure explained in his affidavit[8]
My reference to the sale of the property was not because I (or the Doma Group) was then contemplating a sale of the Glasshouse after construction was complete. On the contrary, our intention was to retain it as an investment asset.
At the time, the Doma Group had extensive loan facilities with St George and was discussing further facilities including the Glasshouse construction loan and the upcoming Hotel Realm and Realm Precinct loans. The combined expected facilities would exceed the prudential limit set by St George on loans to an individual client, but St George's officers advised that they were confident that the prudential limits would be raised for us. The central purpose of my letter was to have this limit raised by pointing out that the risks to the Bank in raising the limits were very small. If there was a concern in future with the limit, it would be easy to remove the Glasshouse and its associated loan from St George's scope or concern. The greater concern for the Doma Group at the time was that St George would be positioned to finance the development and construction of the Realm Precinct in Barton, which was roughly four times the scale of Glasshouse, as it was our preferred financier. …
37. Further agreements for lease for the Glasshouse were entered into with the Australian Public Service Commission (PSC) in September 2006 for 15 years, and with the Child Support Agency (CSA) in February 2007 - although the CSA agreement has an effective date of December 2006. These agreements meant that by late 2006 tenants had been secured for the whole of the Glasshouse building.
38. Construction was substantially complete by August 2006. The final Certificate of Occupancy was issued in about October 2007 when the final incoming tenant finished the fitout of its floors.
SALE OF THE GLASSHOUSE
39. From about 2001 Jure Domazet would receive, from time to time, unsolicited offers for the purchase of the Woden carpark site and then the Glasshouse. He rejected the offers because, he said, it had always been his intention, and the intention of the Doma Group, to retain the Woden carpark and then the Glasshouse as part of the Doma Group's income producing commercial property assets[9]
40. In November 2004 the Doma Group received some advice on the taxation consequences of any future sale of the Glasshouse[11]
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the tax consequences of that distinction was inadequate[12]41. In September 2005 Mr Powderly prepared a 'Strategy Paper' which was sent to Jure Domazet and which outlined three 'Disposal Options' for the Glasshouse[14]
42. Jure's response to the Strategy Paper was to meet with Mr Powderly and inform him that while he appreciated the analysis, the intention of the Doma Group was to build up its commercial property investment portfolio, with the Glasshouse forming a core part of this. Jure said in his affidavit[17]
We had no interest in selling the asset. I also advised him that we did not need to sell Glasshouse to access equity as we had significant capacity to borrow further funds against the Glasshouse and other assets in the Doma Group. Finally, I advised that his approach had potential tax consequences that he had not considered in his advice. In summary, following Ivan's original residential property investment strategy, selling the Glasshouse would just result in significant commission and tax being paid, whereas we could access reasonably equivalent funds through debt and then the income produced by the Glasshouse.
43. Mr Powderly persisted, which prompted Jure Domazet to ask the accountants to provide an analysis of the tax consequences arising from the scenarios in the Strategy Paper. Jure said this was not because he had formed the intention to sell the Glasshouse, but to enable him to respond more definitively to Mr Powderly's Strategy Paper[18]
44. Consistent with Jure's claim that the Doma Group intended to retain the Glasshouse is a St George Bank document dated 29 August 2006[19]
45. Jure said that it was not until this time, August 2006, that he started seriously considering selling the Glasshouse. Colliers had valued the building at $61 million in July 2006 and towards the end of that month the Doma Group received an offer of $63 million but it did not act on that offer. When Mirvac offered $70 million in August 2006 Jure was starting to think that the Canberra commercial office property market was becoming overheated[20]
Against this background, I formed the view that there would be a risk in failing to sell the Glasshouse at the high prices which were being offered at that time because there was, I considered, a significant risk that those prices would not prove not sustainable (sic) over the medium to longer term.
46. Nevertheless, he said he still needed to convince his father, who was reluctant to sell[22]
47.
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A subsequent offer of $77 million for the Glasshouse, by an alternative buyer, was not accepted because, Jure said, 'I continued to prefer the Mirvac offer because it offered the Doma Group the opportunity to acquire high quality, substitute investment commercial property assets for the Glasshouse'[25]48. In June and July 2007 contracts for the sale of the four properties were exchanged. The final sale price of the Glasshouse (after adjustments) was $72.3 million. Settlement took place on 19 July 2007.
CONSIDERATION OF THE REVENUE/CAPITAL ISSUE
49. The authorities have established the following propositions in relation to the question whether a profit from the sale of property is assessable as ordinary income under s 6-5 of the Income Tax Assessment Act 1997 (the 1997 Act), or is in the nature of a capital receipt:
- (a) A distinction is drawn between the mere realisation of a capital asset, and an act done in the carrying on, or carrying out, of a business:
Californian Copper Syndicate v Harris (1904) 5 TC 159 at 166-167;
Commissioner of Taxation v Whitford's Beach Pty Limited (1982) 150 CLR 355 at 367, per Gibbs CJ; - (b) Unless a sale of property is made in an operation of business, the resulting profit will not be income according to the ordinary concepts and usages of mankind: Whitford's Beach, at 372, per Mason J;
- (c) If the sale in question is a business operation, carried out in the course of the business of profit-making, the profit arising on the sale will be of an income character:
London Australia Investment Company Limited v Commissioner of Taxation (1977) 138 CLR 106, at 116, per Gibbs J; - (d) A profit or gain made as a result of an isolated venture or a 'one-off' transaction will constitute income if the property generating a profit or gain was acquired in a business operation or commercial transaction for the purpose of profit-making by the means giving rise to the profit:
Commissioner of Taxation v The Myer Emporium Limited (1987) 163 CLR 199 at 210; - (e) Where a transaction occurs outside the scope of ordinary business activities, it will be necessary to find, not merely that the transaction is 'commercial' but also that there was, at the time it was entered into, the intention or purpose of making a relevant profit:
Westfield Limited v Commissioner of Taxation (1991) 28 FCR 333, at 342, per Hill J (Lockhart and Gummow JJ agreeing), summarising Myer.
50. The authorities use slightly different formulations but they all note the requirement to identify what the business in question comprises. Indeed, in London Australia, Jacobs J said at 127:
The identification and characterization of the business carried on by the taxpayer is the essential task.
51. As Gibbs J said in the same case, at 116, recalling the language used in
Western Gold Mines NL v Commissioner of Taxation (WA) (1938) 59 CLR 729 at 740:
[I]t is necessary 'to make both a wide survey and an exact scrutiny of the taxpayer's activities'.
52. A wide survey and an exact scrutiny of the activities of the Doma Group shows that the relevant, but quite discrete, activities carried on by the Group have been:
- (a) the acquisition, development and sale of residential properties;
- (b) the acquisition and development of residential properties to hold as capital assets for the purpose of the derivation of rental income;
- (c) the acquisition, development and sale of commercial properties;
- (d) the acquisition of commercial properties to hold as capital assets for the purpose of the derivation of rental income; and
- (e) the acquisition and development of commercial properties to hold as capital assets for the purpose of the derivation of rental income.
53. I consider it appropriate to examine the activities of the Doma Group overall, rather than the activities of Investments alone, but I would have made the same findings if I had undertaken that narrower survey.
54.
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Properties are generally earmarked by the Group specifically for one of those activities identified at [52] above. The site of the Woden carpark (which later became the Glasshouse) was, at the time of acquisition, earmarked for activity (d). That is what both Ivan and Jure said it was earmarked for. What they said makes sense. The carpark site was acquired as part of a package with the Sirius Building, which they said they wanted (and expected) to lease for some years. I accept their evidence. If it had been the intention at the time of acquisition to develop the carpark site (which it was not), then I would have said that the property was earmarked for activity (e). The decision to develop the site was made a few years after the acquisition, but the purpose was still to retain the developed site and derive rental income from it. Again, that is what Ivan and Jure said, and I accept it. What they said is consistent with the contemporaneous St George Bank document dated 29 August 2006[26]55. My view of the proper characterisation of the Doma Group's business activities means that I must reject the Commissioner's submissions that the Group was carrying on 'a business of the acquisition, development and disposal of properties or, alternatively, a business which included investing in property assets'[27]
56. Neither of those characterisations, in my view, can be sustained on a proper wide survey and exact scrutiny of the Group's activities, because they fail to acknowledge the discrete nature of the different activities that the Group was undertaking.
57. The first of those characterisations could hardly be less exact. It is so generalised as to be quite misleading. Admittedly, the Doma Group did all of those things - acquisition, development and disposal - but it did not do all of them with respect to all of its properties. To say that that was its business is to avoid the very careful examination of its activities that was mandated by the High Court in Western Gold Mines. It is plain from the evidence of both Ivan and Jure, which in this respect I accept, that there had been for many years, and including during the relevant period, an approach of carefully assessing the best use of a particular property and then putting the property to that use. The Commissioner attempted to gloss over that approach, suggesting that in reality what the Group was doing was to acquire a property, develop it, and then sell it when the market was right. That led the Commissioner to suggest that the reason a property would not be sold reasonably soon after its development was that the Group could not obtain a high enough price for it. That suggestion is contrary to the evidence, and I reject it.
58. The second characterisation - that the Group was carrying on a business which included investing in property assets - is unhelpful. Like the first characterisation, it ignores the discrete nature of the Group's different activities and the specific allocation of a given property to an identified activity. If such a simplistic label were correct then the distinction between revenue gains and capital gains would be meaningless for any entity that carried on a business 'which included investing in property assets'. I do not see how that can possibly be so.
59. As a further alternative, the Commissioner submits[28]
[E]ven if the Domazet Family Trust was not carrying on either of the businesses identified above, the Woden Car Park was part of a profit-making scheme; namely, it was a commercial acquisition and the trustee of the Domazet Family Trust acquired it with a profit-making intention which included not only the receipt of lease income, but other possibilities, including development and sale, as occurred: the Glasshouse was constructed and ultimately sold.
60. The 'possibilities' to which the Commissioner refers are remote, and not at all contemplated. It is, of course, always possible that the owner of an asset will sell it, but to elevate that possibility here into an intention to make a profit by selling the property is to draw a long bow indeed. The Commissioner ran a similar argument in Westfield, and it was rejected by the Full Court:
(1991) 28 FCR 333 at 338-341.
61.
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The fact is, in the case before me, that circumstances presented themselves which made selling the property a sensible thing to do, despite the desire and intention to retain the property as an income-generating asset, and despite Ivan's resistance to selling it. The price was simply too good. And it is relevant to note that the three properties acquired on disposal of the Glasshouse are still owned by the Doma Group, almost nine years after the transaction[29]62. The position is well explained in Myer,
163 CLR 199 at 213 (emphasis added):
[O]ver the years this Court, as well as the Privy Council, has accepted that profits derived in a business operation or commercial transaction carrying out any profit-making scheme are income, whereas the proceeds of a mere realization or change of investment or from an enhancement of capital are not income:
Ruhamah Property Co Ltd v Federal Commissioner of Taxation [1928] HCA 22; (1928) 41 CLR 148, at pp 151-152, 154;
McClelland v Federal Commissioner of Taxation [1970] HCA 39; (1970) 120 CLR 487, at pp 495-496;
London Australia Investment Co Ltd v Federal Commissioner of Taxation [1977] HCA 50; (1977) 138 CLR 106, at pp 115-116; and see Whitfords Beach.The proposition that a mere realization or change of investment is not income requires some elaboration. First, the emphasis is on the adjective "mere" (Whitfords Beach, at p.383). Secondly, profits made on a realization or change of investments may constitute income if the investments were initially acquired as part of a business with the intention or purpose that they be realized subsequently in order to capture the profit arising from their expected increase in value - see the discussion by Gibbs J in London Australia, at pp.116-118. It is one thing if the decision to sell an asset is taken after its acquisition, there having been no intention or purpose at the time of acquisition of acquiring for the purpose of profit-making by sale. Then, if the asset be not a revenue asset on other grounds, the profit made is capital because it proceeds from a mere realization. But it is quite another thing if the decision to sell is taken by way of implementation of an intention or purpose, existing at the time of acquisition, of profit-making by sale, at least in the context of carrying on a business or carrying out a business operation or commercial transaction.
63. The highlighted sentences from that excerpt are enough to dispose of the Commissioner's argument here.
64. It will be clear from the conclusions I have reached that I accept Ivan's and Jure's evidence with respect to the intended use of the Glasshouse property. For completeness, I also note that I accept:
- (a) Jure's explanation, quoted at [36] of these reasons, for his reference to the potential sale of the property in his communication to the St George Bank in October 2005;
- (b) Jure's explanation, referred to at [40] of these reasons, for seeking the taxation advice in November 2004;
- (c) Jure's explanation, referred to at [43] of these reasons, for requesting an analysis of the tax consequences arising from the scenarios in Mr Powderly's Strategy Paper; and
- (d) Jure's evidence, referred to at [47] of these reasons, concerning his preference for the Mirvac offer over the subsequent, higher offer for the Glasshouse.
65. With respect to point (b), the Commissioner invited me to draw a Jones v Dunkel[30]
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The only proper inference to draw from the taxpayer's decision not to call Mr Peatey is that the taxpayer did not consider corroboration of Jure's evidence necessary. As things have turned out, that perception was well founded. I agree with the submission made by counsel for the taxpayer, Mr Hmelnitsky SC, that if the Commissioner thought that Mr Peatey's evidence might undermine Jure's evidence then the Commissioner should have called Mr Peatey for that purpose.CONCLUSION
66. The transaction by which the Glasshouse was disposed of was not a transaction undertaken in the ordinary course of the Doma Group's business activities, having regard to the scope of those activities as identified in [52] of these reasons. Nor was the property acquired for the purpose of profit-making by sale: see Myer,
163 CLR 199 at 209.
67. It follows that the profit from the sale of the Glasshouse was a capital gain.
68. The Commissioner conceded that, because of the matter referred to in [4] of these reasons, and irrespective of the outcome with respect to the substantive issue, there is no 'shortfall amount', within the meaning of s 284-80 in Schedule 1 to the Taxation Administration Act 1953, on which penalties can be imposed.
DECISION
69. The objection decision with respect to primary tax is set aside. The matter is remitted to the Commissioner for reconsideration in accordance with a direction that the profit from the sale of the Glasshouse was a capital gain.
70. The objection decision with respect to administrative penalty is set aside. Instead the objection is allowed in full.
Footnotes
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