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<h1>Impermissible avoidance arrangement permits recharacterisation and disregard of steps and parties to deny inappropriate tax benefits.</h1> 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.