Catchwords:

TAXES AND DUTIES – payroll tax – employment agents – interpretation of s 37(1) of Payroll Tax Act 2007 (NSW) – where Chief Commissioner sought to overturn construction determined by UNSW Global Pty Ltd v Chief Commissioner of State Revenue [2016] NSWSC 1852 – construction consistently applied in subsequent cases – numerous subsequent amendments to legislation – some amendments had materially altered the operation of employment agency contract provisions – construction not shown to be unworkable or untenable – legislation harmonised with other jurisdictions – construction in UNSW Global not departed from