Part IVA anti-avoidance provisions: where is the line now between legitimate tax planning and tax avoidance?

Part IVA was originally introduced to target tax avoidance arrangements that were ‘blatant, artificial or contrived’. Following the 2013 amendments, the focus has shifted to identifying arrangements where the substance of the transaction ‘could more conveniently, or commercially, or frugally have been achieved by a different transaction or form of transaction’. The Commissioner notes, in … Continue reading Part IVA anti-avoidance provisions: where is the line now between legitimate tax planning and tax avoidance?