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Applying Part IVA


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.

Author profile

William Thompson CTA
Bill works for Minter Ellison as Tax Practice Head and Managing Partner of the firm's Brisbane office. Bill is a past National Chair of the Taxation Committee Law Council of Australia, a past Chair of the Taxation Institute of Australia, Queensland Division and has been an executive officer of the Taxes Section of the International Bar Association. Bill advises Australian and international clients in structuring and transactional tax matters, and has particular experience in taxation disputes including litigation to appellate level in the Federal and Queensland jurisdictions. He is well known as a presenter on tax issues in Australia and has been an invited speaker for tax conferences of the IBA, the American Bar Association Tax Committee (Foreign Lawyers) and the Taxation Academy of Singapore. - Current at 02 July 2012
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