This presentation covers:
- the basic rule " ss815-130(1)
- the first exception " ss815-130(2)
- what is the meaning of the words form' and substance'?
- substance over form in the United States
- what is an inconsistency between form' and substance'?
- what is the effect of disregarding some or all of the form' of the commercial or financial relations?
- relevance of OECD TP Guidelines " s815-135
- steps companies should be taking to document and support their tax governance.