General anti-avoidance rule allows recharacterisation of arrangements and application to individual steps to address tax avoidance. The provision establishes the scope of the General Anti-Avoidance Rule, allowing an assessee's arrangement to be declared an impermissible avoidance arrangement and the tax consequences to be determined under the Chapter; the Chapter may be applied to any step in, or part of, the arrangement as it is applicable to the arrangement as a whole.
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 allows recharacterisation of arrangements and application to individual steps to address tax avoidance.
The provision establishes the scope of the General Anti-Avoidance Rule, allowing an assessee's arrangement to be declared an impermissible avoidance arrangement and the tax consequences to be determined under the Chapter; the Chapter may be applied to any step in, or part of, the arrangement as it is applicable to the arrangement as a whole.
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