Impermissible avoidance arrangement permits recharacterisation and disregard of steps and parties to deny inappropriate tax benefits. Where an arrangement is declared an impermissible avoidance arrangement, tax consequences may be determined as deemed appropriate, including disregarding, combining or recharacterising steps; treating the arrangement as not entered into; treating accommodating or connected persons as one; reallocating accruals, receipts, expenditures, deductions or reliefs among parties; treating residence or situs differently; and looking through corporate structures, together with powers to treat equity as debt, reclassify capital and revenue receipts, and recharacterise expenditures or reliefs.