Impermissible avoidance arrangement: arrangements lacking commercial substance trigger anti-evasion rules and recharacterisation measures apply.

Anti-evasion definitions establish that an accommodating party is any participant who derives amounts that alter another party's taxable position; an arm's length price is the market-equivalent price between unrelated parties; associated enterprises and associated person identify control, ownership and influence thresholds; and an impermissible avoidance arrangement is one whose main purpose is to obtain a tax benefit and which creates non-arm's-length rights, misuses the Code, lacks commercial substance, or is not undertaken for bona fide means.

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