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Part IVA - Analysis and statutory construction paper


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 20 years experience in providing legal advice on taxation matters. He is a Senior 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, (including independent review and GAAR panel processes), briefs counsel and provides client support on anti-avoidance matters. Eddy has also advised a number of multinational organisations on audit issues involving international tax matters, cash repatriation, investment structuring, withholding taxes and treaty issues. Eddy also has an interest in the taxation of intellectual property and the anti-avoidance provisions in Australia and has written numerous papers on the topic. Eddy is a member of the National Council of The Tax Institute and also a member of the NSW State Council. - Current at 24 October 2019
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Harish Ekambareshwar
Harish is a Senior Solicitor at PwC. - Current at 23 October 2013
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Caleb Khoo
Caleb is a Legal Partner in the PwC Australia, Tax Controversy Group. Caleb has significant experience in complex tax audits and disputes with the Australian Taxation Office. This includes litigation before the High Court of Australia, Federal Court of Australia and the Administrative Appeals Tribunal. It also includes the use of alternative dispute resolution mechanisms and settlement negotiations to resolve large and complex audits and disputes prior to and in the course of litigation proceedings. Caleb has represented large corporations across a number of industries including mining, infrastructure and construction, telecommunications and consumer goods. He has provided legal advice and services concerning the application of income tax laws, transfer pricing rules, general anti-avoidance rules, tax treaties and administrative law. He has briefed and continues to work with global industry leading experts in banking and finance in preparation for debt pricing disputes. - Current at 23 November 2017
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This was presented at Corporate Tax Masterclass .

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