Impermissible avoidance arrangement determinations now within Authority's scope, expanding pre-emptive review of proposed arrangements by resident or non-resident. The amendment empowers the Authority to determine whether a proposed arrangement by any person, resident or non-resident, is an impermissible avoidance arrangement under the applicable anti-avoidance chapter, enabling pre-transaction assessment; related procedural language is adjusted from conjunctive to disjunctive and an additional sub-clause links the new determination to the advance-ruling eligibility criteria.
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Provisions expressly mentioned in the judgment/order text.
Impermissible avoidance arrangement determinations now within Authority's scope, expanding pre-emptive review of proposed arrangements by resident or non-resident.
The amendment empowers the Authority to determine whether a proposed arrangement by any person, resident or non-resident, is an impermissible avoidance arrangement under the applicable anti-avoidance chapter, enabling pre-transaction assessment; related procedural language is adjusted from conjunctive to disjunctive and an additional sub-clause links the new determination to the advance-ruling eligibility criteria.
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