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of <h1>Tax authority may apply wide anti-avoidance measures: disregard, recharacterise, combine steps, treat parties as one, reallocate tax items</h1> Where an arrangement is declared an impermissible avoidance arrangement, tax consequences including denial of tax or treaty benefits may be determined in any manner deemed appropriate to the circumstances, including disregarding, combining or recharacterising steps or the whole arrangement; treating the arrangement as if not entered into; disregarding or treating accommodating parties as identical with others; deeming connected persons as one; reallocating receipts, accruals, expenditures, deductions or reliefs among parties; recharacterising residence or situs of assets or transactions; looking through corporate structures; and treating equity as debt (or vice versa) or reclassifying capital and revenue items.
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