本研究主要针对1936年《PT IVA所得税评估法案》(ITAA) (ss177A至177H)中针对澳大利亚所得税的一般反避税规则(GAAR)。它将集中在西里尔和西里尔之间的关系和他之前的交易与他的决定。此外，这些关键因素将被确定和描述-避税，逃税，税收规划和要素的PT IVA，以适用于安排。
如西里尔跟随其财务顾问出售其股份，并在抵销资本利得时引发资本损失，则如西里尔的税项利益与资本损失有关，专员有权取消西里尔的税项利益。在这种情况下，一般反避税条款在Pt IVA ITAA36将不适用于此交易。然而，当西里尔使用借来的资金购买ABC银行的股票时，他可以得到扣除，而Pt IVA ITAA36将适用。
essay写手招聘 ：PT IVA所得税评估法案
This research focuses on the General anti avoidance rules (GAAR) for Australia income tax purposes are contained in PT IVA Income Tax Assessment Act 1936 (ITAA) (ss177A to 177H). It will focus on Cyril and the relationship between Cyril and the transaction he preceded with his decision. Also, those key factors will be identified and described–tax avoidance, tax evasion, tax planning and the elements of PT IVA, to apply to an arrangement.
Cyril can be securing tax deduction with the borrowed money to be investing in an offshore company. For this, there is necessity for Cyril to be interposing a resident Australian company. Cyril can use borrowed funds in buying shares in ABC Bank. He can get deductions on the borrowed funds he used to buy shares in ABC Bank.
It is important to determine whether an alternative of postulate is reasonable to carry out or enter into of the scheme. There should not be any regard with respect to the tax costs by the scheme for the taxpayer or the generation of it would be for the taxpayer for anyone else. In a nutshell, the liabilities of the potential tax should not be considered to assess the reasonableness or the likelihood of any alternate postulate.
The resultant of this if applied to Cyril, shows the assumptions of Cyril in terms of using borrowed funds to buy share in ABC Bank must not be rejected. This is because, postulates which are unreasonable in relation to the consideration of the involved tax costs to undertake those postulates would cause Cyril to either indefinitely defer or abandoning the schemes with wider transactions.
In case, Cyril follows his financial advisor in selling his shares and triggering capital losses in offsetting capital gains, the Commissioner is authorized to cancel the Cyril’s tax benefit if the tax benefit of Cyril is in relation to capital in relation to capital loss. In such a situation general anti-avoidance provisions in Pt IVA ITAA36 would not apply to this transaction. However, when Cyril uses borrowed funds in buying shares in ABC Bank, he can get deductions and the Pt IVA ITAA36 would apply.