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) 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) whether the means of achieving those results involves one or more contrived or abnormal steps; and
(3) whether the arrangements are intended to exploit any shortcomings in those provisions3.
Specific examples of indications that tax
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