Clause 184 - Interpretation.

General anti-avoidance rule definitions clarify accommodating parties, arrangements, connected persons, substantial interest and scope of tax benefit.

Clause 184 frames core definitions for the General Anti-Avoidance Rule: an accommodating party is one whose main purpose in an arrangement is to obtain a tax benefit for the assessee; arrangement covers any step, transaction, scheme or understanding including alienation of property; fund, asset, benefit and step are broadly defined. The clause defines connected person and relative relationships, sets objective tests for when a person has a substantial interest in a business, and defines tax benefit to include reductions, avoidance, deferral or increased refunds of tax under the Act or tax treaties, plus reductions in total income or increases in loss.