Client Alert
Full Federal Court overturns S.N.A Group ‘service fee’ deduction win: evidence of mutual assent to contract is critical
In July 2025, we wrote about the Federal Court’s decision in S.N.A Group Pty Ltd v Commissioner of Taxation [2025] FCA 240, which was widely seen as a ‘commercial reality’ endorsement for inter entity service fee arrangements in closely held groups – where documentation is known to be imperfect.