Impermissible avoidance arrangement: tax consequences are determined only with reference to the specific part so characterised. For the purposes of section 181, where only part of an arrangement is declared to be an impermissible avoidance arrangement, the tax consequences are determined with reference to that part alone. The rule confines the analysis to the specific component of the arrangement that has been so characterised, rather than the entire arrangement.
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.
Impermissible avoidance arrangement: tax consequences are determined only with reference to the specific part so characterised.
For the purposes of section 181, where only part of an arrangement is declared to be an impermissible avoidance arrangement, the tax consequences are determined with reference to that part alone. The rule confines the analysis to the specific component of the arrangement that has been so characterised, rather than the entire arrangement.
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