General anti-avoidance rule: impermissible arrangements may be recharacterised, disregarded and tax benefits denied or reallocated among parties. Where an arrangement is declared an impermissible avoidance arrangement, tax consequences including denial of tax or treaty benefits are to be determined ... Summary
General anti-avoidance rule: impermissible arrangements may be recharacterised, disregarded and tax benefits denied or reallocated among parties.
Where an arrangement is declared an impermissible avoidance arrangement, tax consequences including denial of tax or treaty benefits are to be determined as appropriate to the circumstances. Responses may include disregarding, combining or recharacterising steps, treating the arrangement as not entered into, collapsing accommodating parties or connected persons into one, reallocating accruals or deductions among parties, recharacterising equity and debt or capital and revenue receipts, and reattributing residence or situs or looking through corporate structures.
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