Part IVA – General Anti-avoidance

The application of Part IVA to a transaction/structure is a daunting prospect for taxpayers and advisors alike.  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.

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

Suited to:

• Firms of all sizes will benefit from this session
• Advisors with limited exit ACA experience will benefit from the overview of the process, whilst those with intermediate levels of experience will benefit from the refresher and practical tips

This On Demand recording Includes: 

• Recording of the Live Webinar, which can be viewed multiple times, for as long as required 
• Presenters contact details for follow up questions 
• CPD Quiz
• CPD Certificate 
• CPD Report – Logged automatically 
• PowerPoint Presentation
• Verbatim Transcript, with Searchability
• Supporting Documentation