600. The double reasonableness test for abusiveness.

The legislation says that tax arrangements1 are abusive if they cannot reasonably be regarded as a reasonable course of action in relation to the relevant tax provisions, having regard to all the circumstances2, including:

  1.  

    (1)     whether the substantive results of the arrangements are consistent with any principles on which those provisions are based (whether express or implied) and the policy objectives of those provisions;

  2.  

    (2)     whether the means of achieving those results involves one or more contrived or abnormal steps; and

  3.  

    (3)     whether the arrangements are intended to exploit any shortcomings in those provisions3.

Specific examples of indications that tax