Australian labour law concerns Commonwealth, state, and common law on rights and duties of workers, unions and employers in Australia. Australian labour law (also known as industrial relations law) has a dual structure, where some employment issues and relationships are governed by Commonwealth (the Australian federal government) laws, and others are governed by state and territory laws or the common law. It shares a heritage with laws across the Commonwealth of Nations, UK labour law and standards set by the International Labour Organization, the Australian legislature and courts have a built a comprehensive charter of rights at work. Constitutional basis The conciliation and arbitration power of the Commonwealth was originally based on Section 51(xxxv) of the Constitution of Australia, which provides: "The [Commonwealth] Parliament shall, subject to this Constitution, have power to make laws for the peace, order, and good government of the Commonwealth with respect to: (xxxv) conciliation and arbitration for the prevention and settlement of industrial disputes extending beyond the limits of any one state". The Commonwealth's power to make laws about labour law under the conciliation and arbitration power was seen as being extremely narrow and limited. The Commonwealth government sought to widen its industrial powers by other means. For example, in 1906 two bills were introduced that would become the Customs Tariff Act 1906, and the Excise Tariff Act 1906 which exempted manufacturers who paid "fair and reasonable" wages to their employees from these duties. The Commonwealth Court of Conciliation and Arbitration in the Harvester case (1907) was required to determine what were "fair and reasonable" wages, but the High Court of Australia in R v Barger (1908) struck down the government's strategy of using the taxation power to enact labour laws as invalid. The Barger decision was made in the context of the then prevailing reserved State powers doctrine, which was itself overturned in 1920 in the Engineers case. Since 2005, Australian industrial relations laws, such as WorkChoices, have been primarily based on the corporations power in section 51(xx) of the Constitution, which enables labour laws to be of much wider reach, without the constraints imposed by the conciliation and arbitration power. The corporations power gives the federal parliament power to make laws with respect to "trading and financial corporations formed within the limits of the Commonwealth", as well as 'foreign' corporations. History Commonwealth Court of Conciliation and Arbitration The Commonwealth passed the Commonwealth Conciliation