- Aug 9, 2016
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You stated yourself that the purpose of declaring the dividend was to avoid paying tax, did you not?
If the purpose of the arrangement is to avoid paying tax it will get caught by Pt IVA every day of the week, & twice on Sunday.
The test isn't whether I'm motivated by tax saving the test is whether an objective third party would conclude on the balance of evidence that the dominant purpose was tax benefit. I've been doing this for 38 years I know where the line is. This isn't even remotely controversial in those terms and is why it's so powerful. Hey but you stick with what you 'know'. Much better for us both I think