Part IVA is a fundamental part of our tax system, although one that many practitioners don’t really understand in any detail. It is a provision that impacts every tax decision, every bit of planning, every piece of structuring, yet so often, practitioners don’t know where to start when assessing the potential impact that Pt IVA could have. The objective of this guide is to provide practitioners with a robust, practical framework within which to approach Pt IVA issues.
Additionally, the guide covers: the practicalities of the key elements of Pt IVA (scheme, tax benefit, alternative postulate and dominant purpose); the main cases decided in respect of Pt IVA, with an explanation of the core “takeaways” for each case; the practical impact of the recent legislative changes to Pt IVA; and tips for dealing with the ATO on a Pt IVA situation.
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