Righto, as well as looking up Part IV A and Central Management and Control, please add "Beneficial ownership" to the list of tax terms you completely don't understand.
JK has beneficial ownership in a BVI entity. The BVI entity owns shares in... ISX!
Regardless of his internal structure, JK had (through an interposed entity) a shareholding in ISX worth millions (or hundreds of millions depending on the value). Now he (through an interposed entity) has a shareholding in ISXFEU worth money, and a shareholding in ISX worth almost nothing.
And at the end of the day, even if I cared about the outcome of the ATO case, your interpretation of what the judge thinks is really not a concern of mine.
Also - constantly pointing out that JK maintains his shareholding through a tax haven probably isn't helping your point. Again - please refer to part4a.
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