The High Court in Avowal Administrative Attorneys Limited and Ors v. The District Court at North Shore and the Commissioner of Inland Revenue (CIV-2006-404-007264) (2007 unreported interim judgment) has held that Art. 26 of the Australia-New Zealand tax treaty (hereafter "the treaty") prevents discovery by a taxpayer against the New Zealand Commissioner of Inland Revenue (CIR) of documents containing requests by the Australian Tax Office (ATO) to the New Zealand Inland Revenue Department (IRD) for information concerning the taxpayer. Searches of the taxpayer's premises pursuant to the ATO requests for information were made by the IRD on 26 November 2006....