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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 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
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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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