Home / News / Loans, gifts and “red envelope” money: Tribunal confirms onus of proof in case involving tax fraud or evasion.

Loans, gifts and “red envelope” money: Tribunal confirms onus of proof in case involving tax fraud or evasion.

The Administrative Review Tribunal has delivered a decision in favour of the Commissioner of Taxation in proceedings brought by a Western Australia-based mining entrepreneur concerning the treatment of amounts alleged to be related party loans and gifts: ZFPR and Commissioner of Taxation [2025] ARTA 572.

The taxpayer, an experienced company director who moved to Australia from China, claimed that the amounts were hongbao or “red packet money” received from friends/family members, and payments referable to investments and loans. The Commissioner contended that the taxpayer engaged in fraud or evasion.

Following an 8 day hearing, the Tribunal rejected the taxpayer’s case and affirmed the Objection Decision under review, which concerned multiple assessments across 9 years.

The Tribunal addressed the burden of proof borne by taxpayers in Part IVC proceedings. The taxpayer’s reliance on the Full Court’s decision in Commissioner of Taxation v Cassaniti [2018] FCAFC 212 was rejected where “the cross examination entirely undermined the ability of the Tribunal to be confident that the books and records were a true reflection of the transactions they purported to record.”

The decision also addresses an adjournment application made by the taxpayer following the first day of the taxpayer’s 3 day cross-examination, on the basis that the taxpayer wished to replace his legal team.

Greg O’Mahoney and Neha Dubey acted for the Commissioner of Taxation.

The decision can be accessed here:
https://www.austlii.edu.au/cgi-bin/viewdoc/au/cases/cth/ARTA/2025/572.html

Back to all

Latest News

Vinnies CEO Sleepout

Arthur Moses SC will be participating in the Vinnies CEO Sleepout on Thursday, 19 June 2025, to help raise vital funds for homelessness services…

Read more
View all news

Get our news and cases straight to your inbox.

You can unsubscribe anytime. By signing up you agree to our Terms & Condition and Privacy Policy.