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.
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 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.
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