F1PART 3AGENERAL ANTI-AVOIDANCE RULE

Annotations:
Amendments (Textual)

Proceedings before a court or tribunal

81HProceedings in connection with the general anti-avoidance rule

In proceedings before a court or the tribunal in connection with the general anti-avoidance rule, it is for WRA to show—

a

that there is an artificial tax avoidance arrangement, and

b

that the adjustments made (or to be made) to counteract the tax advantage arising from the arrangement are just and reasonable.