The ‘sales of occupation income’ provisions applied for income tax purposes to a capital sum received on the sale of goodwill and other assets to a company. 

Summary 

The ‘sales of occupation income’ provisions (ITA 2007, ss 773-789) applied for income tax purposes to a capital sum received on the sale of goodwill and other assets to a company. 

Background 

The appellant (RG), an actor, started filming the first Harry Potter film in 2001, the year in which he turned 13. RG’s business affairs were managed by RG’s father (NG) from that time until NG’s death. On 1 August 2011: (a) a company (Clay 10) was incorporated, with RG as the sole shareholder and NG as the company’s sole director; and (b) an agreement was apparently concluded for RG to provide services to Clay 10 for the provision of his acting services except in the USA. <