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Impermissible Tax avoidance arrangement, S 80L "any arrangement that,…
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S 80L "any arrangement that, but for the general anti-avoidance rule, results in a tax benefit"
Tax benefit?
S 1 "any avoidance, postponement or reduction of any liability for tax;"
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S 80L "any transaction, operation, scheme, agreement or understanding (whether enforceable or not), including all steps therein or parts thereof, and includes any of the foregoing involving the alienation of property"
legal substance + effect and
-round trip financing 80D;
-accommodating or tax indifferent party 80E
-offsetting or cancelling
Disregard, combine or re-characterise steps;
Disregard accmmmodating or tax-indifferent parties;
deem connected persons to be 1 person
reallocating, re-characterise