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[2022] NSWCA 259
Court of Appeal (NSW)
2022-10-19
Brereton JA, Ward CJ
Original judgment source is linked above.
Ward CJ in Eq File Number(s): 2019/00047367
[Note: The Uniform Civil Procedure Rules 2005 provide (Rule 36.11) that unless the Court otherwise orders, a judgment or order is taken to be entered when it is recorded in the Court's computerised court record system. Setting aside and variation of judgments or orders is dealt with by Rules 36.15, 36.16, 36.17 and 36.18. Parties should in particular note the time limit of fourteen days in Rule 36.16.]
HEADNOTE [This headnote is not to be read as part of the judgment] During the period 1 July 2015 to 30 June 2018 (Relevant Years), the respondent, E Group Security Pty Ltd, provided security services to its customers. The security guards who delivered those services were procured from unrelated subcontracting companies. Those subcontractors were paid by three related entities of the respondent, namely E Group Protective Services Pty Ltd, Vital Hospitality Group Pty Ltd and E Group Events Australia Pty Ltd. The appellant, the Chief Commissioner of State Revenue, assessed the respondent's payroll tax liability for the Relevant Years on the basis that it and its three related entities were party to "employment agency contracts" within the meaning of s 37 of the Payroll Tax Act 2007 (NSW). The respondent sought a review of the appellant's decision in the Supreme Court pursuant to s 97 of the Taxation Administration Act 1996 (NSW). The review focused on the true nature of the relationship between the unrelated subcontracting companies which supplied the security guards, E Group Security and its three related entities, and the clients to which the security services were ultimately provided. The primary judge allowed the respondent's review and revoked the relevant payroll tax assessments. Relevantly, her Honour concluded that the related entities did not "procure" security guards for the respondent as contemplated by the definition of "employment agency contract". Rather, the respondent entered into contracts with subcontractors directly and the related entities served only to pay the subcontractors on the respondent's behalf. In reaching this conclusion, the primary judge primarily relied upon an analysis of the terms and conditions of Group Payroll Agreements which existed between the respondent and its related entities. The Chief Commissioner of State Revenue appealed from that decision. Grounds 1 to 3 of its amended notice of appeal, which related to its primary claim below, were dismissed by the Court in Chief Commissioner of State Revenue v E Group Security Pty Ltd [2022] NSWCA 115. The remaining grounds of appeal, grounds 4 and 5, related solely to the issue whether the "employment agency contracts" provisions in the Payroll Tax Act applied so as to make the respondent liable to pay payroll tax on that basis. In the event the appeal succeeded, the respondent asked the Court to remit the interest on the tax liability on the basis of an alleged representation made by an officer of the Office of State Revenue in January 2015 that "Just engage corporate contractors and you'll be okay. They have to have at least 2 or 3 employees". It contended that, relying on this representation, it terminated all its sole traders and only engaged corporate contractors. The Court held, upholding grounds 4 and 5 of the amended notice of appeal: Whether the "employment agency contract" provisions of the Payroll Tax Act applied The respondent was liable to pay payroll tax on the basis that its related entities procured for it the services of security guards and it was thus subject to the "employment agency contract" provisions of the Payroll Tax Act. Per Brereton JA: The question is not whether there was an "employment agency contract" between E Group Security and its related entities, but whether those payments were made under a contract under which the related entities (as employment agent) procured the services of security guards (service providers) for E Group Security (client): [7]. The evidence (described at [9]-[19]) comprising various invoices and statements; a Group organisational chart; master licences belonging to each related entity; financial statements and income tax returns of the related entities and those of E Group Security; and affidavits filed by E Group Security indicated that the related entities did so procure the services of security guards: [20], [22]. Per Griffiths AJA (Simpson AJA agreeing at [24]): The principal issue was whether the arrangements between E Group Security and its clients (or, alternatively, the arrangements between E Group Security and its related entities) were "employment agency contracts": [26]. Various documents (described at [78]-[94]) indicated that the related entities did more than simply perform a payroll function during the Relevant Years. Rather, there was an arrangement that operated during the Relevant Years whereby the related entities procured security guards for their client, E Group Security: [96]. Whether interest on the payroll tax liability should be remitted Per Griffiths AJA (Brereton JA agreeing at [23], Simpson AJA agreeing at [24]): Even if the representation was made in the terms alleged, it is more probable than not that it related to the effect of Div 7 of Pt 3 of the Payroll Tax Act (which relates to contractors) as opposed to Div 8 (which deals with employment agents): [103]. There were no special circumstances justifying the remission of interest: [99], [104]-[107].
JUDGMENT
Conclusion
Relevant legislative regime summarised
Primary judge's reasons for judgment on the alternative claim
Relevant grounds of appeal
Chief Commissioner
E Group Security
Chief Commissioner's reply
Was there an "employment agency contract" between the Grouped Entities and E Group Security during the relevant years?
Invoices issued by subcontractors for provision of security guards
Various internal documents
E Group Security's statements to clients and third parties
Minutes of E Group Security and the Grouped Entities
Conclusion on the "arrangement"
(b) Should interest on the payroll tax liability be remitted?
Costs
Conclusion
Endnotes
Chief Commissioner of State Revenue
E Group Security Pty Ltd
[2013] VSC 492
(2022) 96 ALJR 89
(2017) 340 ALR 368