When undertaking any tax planning exercise, regard must be had to a whole raft of anti-avoidance legislation. It is tempting to assume that a particular stratagem is unique; often it is not!

The following is a checklist of the main anti-avoidance provisions which could be encountered in a corporate context.


general anti-abuse rule (¶187-850)

Exploitation of tax losses

disallowance of losses on a change in the ownership of a company (CTA 2010, Pt. 14) (¶731-050)

creation of temporary groups to utilise losses (CTA 2010, s. 154–156) (¶740-050)

losses of businesses not carried on with a view to profit (CTA 2010, s. 44) (¶731-350)

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