Published on 01 Apr 07
by "THE TAX SPECIALIST" JOURNAL ARTICLE
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.
William (Bill) D
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