Understanding the way in which the Commissioner can apply the general anti-avoidance rules is imperative.
Undertaking a transaction or setting up a structure will give rise to tax outcomes in accordance with the law. However, Part IVA provides the Commissioner with the power to cancel tax benefits arising from a scheme.
We will consider the key elements to a Part IVA determination, focussing on:
- Key findings from relevant case law
- Calculating a tax benefit – the counterfactual / alternate hypothesis
- The purpose of the taxpayer (and advisors) based on objective evidence
- Penalties applicable
The session will include practical examples for applying Part IVA.
Webinar Learning Outcomes:
- Understand the required elements for a Part IVA determination
- Understand the nature of evidence for determining the purpose of entering a scheme
- Determine a counterfactual scenario in order to calculate a tax benefit
- Taxpayers involved in transactions and restructuring
- Firms of all sizes will benefit from the session
- Advisors with limited experience in Part IVA will benefit from an overview of the key elements, whilst those with intermediate levels of experience will benefit from the refresher.
Paul Mills has worked in the corporate tax practice at PwC for over 20 years, advising clients on a range of transactions.
For the past seven years, Paul has been responsible for PwC’s national tax technical education program. He is now commencing his own tax advisory business.
You will be provided with:
• PowerPoint presentation slide deck
• Any Supporting documentation
• Webinar Recording to view multiple times for up to 6 months
• An opportunity to ask questions to the presenter
The application of Part IVA to a transaction/structure is a daunting prospect for taxpayers and advisors alike.