Related party transactions: Full Court reaffirms that substantiation can win or lose a tax case
In the recent Full Federal Court’s decision in Commissioner of Taxation v S.N.A Group Pty Ltd [2026] FCAFC 10 (“S.N.A Group”), the ATO was successful in challenging the deductibility of intragroup service fees. In this case, payments described as ‘service fees’ continued to be paid after a written agreement between related parties to pay for […]