Blank tape levies


The Federal Court of Appeal in Canada has upheld a "blank tape levy" as a validly enacted regulatory charge and not a tax in Canadian Private Copying Collective v Canadian Storage Media Inc and others [2004] FCA 424 here.

The case concerned a number of other issues here including the rates that could be set and whether particular technologies were covered. However, the principal point of interest from an Australian perspective is that our very own Blank Tapes case was of course considered and, significantly, distinguished.

Given the scale of infringing activity taking place in the digital world, one would hardly need to be Nostradamus to guess that the Australian collecting societies will be banging on the Attorney General's door brandishing copies of this judgment and calling for action.

The first ground of distinction, however, does not seem to change matters. Apparently, under Canadian constitutional law there is a distinction between a tax and a regulatory charge, which the Court of Appeal in Canada considered was not a relevant consideration in Australia (see para. 48). Noel JA went on to consider that the four traditional criteria of a tax which the majority in the Blank Tapes case did apply were all present and correct. In other words, the levy was saved under Canadian law solely because it was a regulatory charge even though it would have been a tax under "traditional" criteria (see para. 53).

Posted: Wednesday - 09 February, 2005 at 06:58 PM         |


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