General anti-avoidance rule permits recharacterisation and disregarding of arrangements to prevent tax benefits and allocation of income and expenses. A general anti-avoidance rule allows the tax authority to declare an impermissible avoidance arrangement and to determine its tax consequences by disregarding, combining or recharacterising any step or part of the arrangement; treating the arrangement as if not entered into or otherwise altering its treatment to prevent the tax benefit; treating or disregarding accommodating parties; deeming connected persons as one; reallocating accruals, receipts or expenditures among parties; and recharacterising equity and capital as debt or revenue where appropriate.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
General anti-avoidance rule permits recharacterisation and disregarding of arrangements to prevent tax benefits and allocation of income and expenses.
A general anti-avoidance rule allows the tax authority to declare an impermissible avoidance arrangement and to determine its tax consequences by disregarding, combining or recharacterising any step or part of the arrangement; treating the arrangement as if not entered into or otherwise altering its treatment to prevent the tax benefit; treating or disregarding accommodating parties; deeming connected persons as one; reallocating accruals, receipts or expenditures among parties; and recharacterising equity and capital as debt or revenue where appropriate.
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