General anti avoidance rule treats connected persons as a single taxpayer and disregards accommodating parties to prevent tax benefit.

The General Anti Avoidance Rule provides that connected persons may be treated as one and the same person when determining a tax benefit; accommodating parties may be disregarded; an accommodating party and any other party may be treated as one and the same person; and arrangements may be looked through by disregarding corporate structure to assess the substantive tax position.

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