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of <h1>General Anti-Avoidance Rule allows tax authority to declare tax-avoidance arrangements impermissible and apply recharacterisation remedies</h1> The Chapter establishes a General Anti-Avoidance Rule allowing the tax authority to declare arrangements impermissible where the main purpose is obtaining a tax benefit and the arrangement creates non-arm's-length rights, misuses the Act, lacks commercial substance, or uses non-bona fide means. Presumptions apply to steps of arrangements. Lack of commercial substance is defined (including round-trip financing, accommodating parties, offsetting elements, disguised transfers, location without commercial purpose, or absent material effect on business risks/cash flows). Remedies include recharacterising, disregarding or combining steps or parties, treating connected or accommodating persons as one, reallocating income/deductions, and looking through structures; guidelines and definitions are prescribed.
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