Anti-avoidance Corporate tax Income tax

Understanding the new Part IVA

Source: QLD

Published Date: 25 Mar 2013


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This paper covers:

  • development of jurisprudence on Part IVA
  • dominant purpose
  • changes to the 'Reasonable Expectation Test' 
  • framing and proving the alternative postulate
  • exclusion of Assessable Income Tax Benefit - The 'Do Nothing' Alternative Postulate 
  • allowable Deduction Tax Benefit – Alternative Postulate 
  • the Commissioner's Grievances with the Alternative Postulate
  • policy
  • basis of amendment to 'reasonable expectation test'
  • Assistant Treasurer’s Announcement - November 2012 and 2013 Amendments
  • Government’s concerns and policy response 
  • key amendments and concepts contained in the 2013 Bill.


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Anti-avoidance Corporate tax Income tax International tax & business Litigation 2013

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