© 2026 Zoe. All rights reserved.
Zoe is a legal information platform. Always consult the Federal Register of Legislation for authoritative text.
[1999] FCA 287
Federal Court of Australia
1999-05-21
Kenny JJ
Original judgment source is linked above.
Introduction 1 On 14 May 1998 the present respondent, the Deputy Commissioner of Taxation, issued a notice under s 264(1)(a) of the Income Tax Assessment Act 1936 (Cth) ("the ITA Act") requiring the appellant, Anthony May, a member of the firm of solicitors, Herbert Geer & Rundle, to furnish him with information relating to matters described in a schedule to the notice. Those matters related to the affairs both of the firm and of its clients past and present. 2 Mr May challenged the validity of the notice in proceedings for an order of review under s 5 of the Administrative Decisions (Judicial Review) Act 1977 (Cth) ("the ADJR Act"). Save as to two severable items referred to in the schedule to the notice, a judge of this Court upheld the validity of the notice. From that decision Mr May appeals to this Court. 3 As prosecuted before us, the appeal raises three separate issues. The first focuses on the impact the notice has on information of and about clients in the hands of the firm and invites a novel fusion of the rules of natural justice and the obligation of a decision-maker to take relevant considerations into account. It alleges that clients of the firm have a right to procedural fairness in the exercise of the s 264(1)(a) power such as would give them an adequate opportunity to challenge the validity of its exercise and that a failure by the respondent properly to have regard to that right constitutes a failure to take a relevant consideration into account in the exercise of the power. 4 The second issue in the appeal alleges that the reasons given by the Deputy Commissioner for the exercise of the power do not justify requiring Mr May to provide all of the information sought in the notice. And to issue a notice wider in terms than the purpose for which the power is proposed to be exercised is, it is said, an error of law. 5 The third issue relates to the proper construction to be given s 264(1)(a) of the ITA Act as it applies to information relating to documents, in light of the provisions of s 264(1)(b) that deal directly with the production of documents.
The Statutory Setting 6 We need refer only to s 264(1) of the ITA Act. It provides: "The Commissioner may by notice in writing require any person, whether a taxpayer or not, including any officer employed in or in connexion with any department of a Government or by any public authority: (a) to furnish him with such information as he may require; and (b) to attend and give evidence before him or before any officer authorized by him in that behalf concerning his or any other person's incomeor assessment, and may require him to produce all books, documents and other papers whatever in his custody or under his control relating thereto." 7 The one matter we would emphasise in passing is that it is clear on the face of the subsection that, variously, the "information", "evidence" or "books" etc a person may be required to give or produce need not necessarily relate to the recipient of the notice. It can relate to a third party as, for example in the present case, the clients of a solicitor.
The Factual Setting 8 The notice the subject of this appeal was the outcome of communications between the Australian Tax Office ("the ATO") and Mr May extending over some number of months during which time other s 264(1)(a) notices were served but were withdrawn on service of the present notice. From at least 10 November 1997 Mr May had been made aware that the ATO had in train a national project relating to employee share plans and employee benefit trusts and that its purpose was to determine whether certain legislative amendments, previously made, were effective. Mr May's firm, it should be said, provided legal advice to clients on matters relating to income tax legislation. 9 On 14 May 1998 the respondent wrote a letter to Mr May that enclosed the s 264(1)(a) notice. Insofar as presently relevant the letter stated: "Please note that section 264 does not override legal professional privilege but does override the privilege against self-incrimination. The information requested in the attached notice is requested for the purposes of the Income Tax Assessment Act 1936 and 1997, as amended." 10 The notice required Mr May to furnish to the Deputy Commissioner in writing by a specified date the information described in the schedule to the notice. The schedule requires to be set out in full. "SCHEDULE The following information is requested in relation to all employee share acquisition plans, employee benefits trusts or similar plans which have been established or prepared by Herbert Geer & Rundle in the abovementioned period:
The Issues in the Appeal
Associate: Dated: Counsel for the Applicant: Mr JD Merrells QC with Mr PH Solomon
Solicitor for the Applicant: Herbert Greer & Rundle
Counsel for the Respondent: Mr G Davies with Ms J Davies
Solicitor for the Respondent: Australian Government Solicitor
May
Deputy Commissioner of Taxation
(1990) 170 CLR 596
(1985) 159 CLR 550
(1985) 6 FCR 356
(1986) 10 FCR 559
(1990) 170 CLR 649
(1979) 143 CLR 499
(1976) 134 CLR 475
(1989) 20 FCR 403
(1989) 25 FCR 187
(1986) 162 CLR 24
(1990) 170 CLR 321
(1986) 159 CLR 656
(1993) 42 FCR 578
(1997) 76 FCR 151
(1996) 185 CLR 259
(1979) 25 ALR 445
(1936) 55 CLR 499
(1947) 74 CLR 492