Hon DAVID PARKER: —more precise—jurisprudence on the income shifting that occurred under the prior iteration of the 39c in the dollar tax developed pretty late in the piece during the period when that higher rate applied. The case concerned was called Penny and Hooper. In Penny and Hooper, a professional taxpayer diverted quite a bit of his income through an alternative structure in order to minimise his own income and put income through another taxpaying entity. That was found to be tax avoidance, and we are confident that some of the behaviour that was effective at avoiding tax would now be determined to be tax evasion as a consequence of the Penny and Hooper decision, which will still have authority in respect of these changes. 