TMI BlogConsequences of impermissible avoidance arrangement.X X X X Extracts X X X X X X X X Extracts X X X X ..... aty, shall be determined, in the manner as deemed appropriate. (2) The consequences of an arrangement declared to be an impermissible avoidance arrangement as referred to in sub-section (1) shall include but shall not be limited to the following:- (a) disregarding, combining or recharacterising any step in, or a part or whole of, the impermissible avoidance arrangement; (b) treating the imper ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d under the arrangement; or (g) considering or looking through any arrangement by disregarding any corporate structure. (3) In this section,- (a) any equity may be treated as debt or vice versa; (b) any accrual, or receipt, of a capital nature may be treated as of revenue nature or vice versa; or (c) any expenditure, deduction, relief or rebate may be recharacterised. - Clause 181 of t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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