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Coming out of the Dark? The Uncertainties that Remain in Respect of Part IVA: How Does Recent Tax Office Guidance Help?

Nicole Wilson-Rogers

Taxation from ATAX, University of New South Wales

Abstract: This article considers several issues that make the application of Part IVA uncertain and whether recent tax office guidance, in the form of PS LA 2005/24 and the Guide, provide any further clarity on these issues. It is suggested that PS LA 2005/24 and the Guide fail to provide further clarity and this is largely due to the fundamental problem that it is unclear what particular activities Part IVA seeks to target at a policy level. Consequently, Part IVA has been drafted in a manner that is amorphous and uncertain in order to combat these indeterminate activities.

Keywords: Part IVA; tax; anti-avoidance; uncertainty; tax law; tax administration (search for similar items in EconPapers)
Pages: 36 pages
Date: 2006-10-17
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Persistent link: https://EconPapers.repec.org/RePEc:nsw:discus:412

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