The TACS Partnership points out that mistakes about the tax consequences of certain actions can be rectified in some instances.
Tax planning can be hazardous and uncertain. For example, if a tax planning arrangement is considered to overstep the mark, there is a plethora of targeted anti-avoidance rules (TAARs) and less specific anti-avoidance legislation, which can render the planning ineffective for tax purposes.
General anti-abuse rule
Furthermore, the general anti-abuse rule (GAAR) is broadly aimed at counteracting ‘abusive’ tax arrangements (FA 2013, ss 206-215, Sch 43).
The GAAR applies what is commonly known as a ‘double reasonableness’ test. This