Miscellaneous 2007

Applying Part IVA

Source: The Tax Specialist Journal Article

Published Date: 1 Apr 2007

This article examines the principles that are relevant in practical application of Part IVA, by reference to recent case law. Questions remain around the definition of a “scheme”, and whether the identified scheme must be capable of standing on its own two feet as a matter of definition, or whether that is simply a requirement of procedural fairness. Difficulties remain also in correctly applying s 177D(b) to decide whether the objective purpose to be imputed to any party to the scheme was to enable the taxpayer to obtain the identified tax benefit.

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Miscellaneous 2007

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