General anti-avoidance rule enables recharacterisation of arrangements to deny tax benefits and treat connected parties as one.

General Anti-Avoidance Rule allows declaration of an arrangement as an impermissible avoidance arrangement where its main purpose is to obtain a tax benefit, evidenced by non-arm's-length rights or obligations, misuse or abuse of the Act, lack of commercial substance, or atypical means. Lack of commercial substance includes discrepancies between substance and form, round-trip financing, accommodating parties, offsetting elements, concealment of funds, location choices solely for tax reasons, or absence of business-risk or cash-flow effects. Tax consequences may include disregarding, combining or recharacterising steps, treating parties as one, reallocating amounts, and looking through structures.

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