Commentary

D9.524 Anti-avoidance

Corporate tax
Corporate tax | Commentary

D9.524 Anti-avoidance

Corporate tax | Commentary

D9.524 Anti-avoidance

Special rules apply to prevent manipulation of the acquisition or disposal values of a strip where, under a scheme or arrangement1:

  1.  

    (a)     the amount paid for the acquisition of a strip is more than its market value at the time of acquisition; or

  2.  

    (b)     the amount paid on a transfer of a strip is less than its market value at the time of transfer; or

  3.  

    (c)     the amount payable on redemption of a strip is less than its market value on the day before redemption; and

  4.  

    (d)     the main benefit or one of the main benefits that might

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