High Court decision on Australia-New Zealand tax treaty

The High Court in Avowal Administrative Attorneys Limited and Ors v. The District Court at North Shore and the Commissioner of Inland Revenue (CIV-2006-404-007264) (2007 unreported interim judgment) has held that Art. 26 of the Australia-New Zealand tax treaty (hereafter "the treaty") prevents discovery by a taxpayer against the New Zealand Commissioner of Inland Revenue (CIR) of documents containing requests by the Australian Tax Office (ATO) to the New Zealand Inland Revenue D…