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Part IVA - Analysis and statutory construction paper

Published on 21 Nov 13 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • the new tax benefit test
  • annihilation versus reconstruction
  • has the relationship between the 3 elements changed
  • the do nothing defence
  • the evidentiary process
  • the EM and its role.

Author profiles

Eddy Moussa CTA
Eddy is a practising tax lawyer with over 18 years experience in providing legal advice on taxation matters such as financing, international and domestic restructuring and merger and acquisition transactions. Eddy is a partner in the PwC Tax Controversy team. He provides legal advice to mainly multinational clients on taxation matters (including anti-avoidance), and supports clients in resolving disputes with the Australian Taxation Office. This work involves assisting clients under audit or investigation. Eddy also leads alternative dispute resolution processes, briefs counsel and provides anti-avoidance opinions. Eddy has also advised a number of multinational organisations on international tax issues including cash repatriation, investment structuring, withholding tax and treaty issues. Eddy also has an interest in the taxation of intellectual property in Australia and has written papers on the topic. Eddy is Deputy Chair on the NSW State Council of the Tax Institute of Australia and the Co-Chair on the NSW Professional Development Committee of the Tax Institute of Australia and has published papers on taxation anti-avoidance. - Current at 11 October 2017
Click here to expand/collapse more articles by Eddy MOUSSA.
Harish Ekambareshwar
Harish is a Senior Solicitor at PwC. - Current at 23 October 2013
Click here to expand/collapse more articles by Harish EKAMBARESHWAR.
Caleb Khoo
Caleb is a Senior Associate at PwC. - Current at 23 October 2013

 

This was presented at Corporate Tax Masterclass .

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