Commentary on Sections Overview Overview
2023.This Chapter rewrites, for the purposes of income tax, sections 703 to 709 of ICTA.
2024.Sections 703 to 709 of ICTA were enacted as a wide-ranging anti-avoidance rule which would enable the Crown to counter all manner of devices to avoid income tax involving transactions in shares or other securities or the manipulation of a company’s assets or both, and to forestall the creation of such devices in future.
2025.The sections of this Chapter are arranged in the following order:
	Sections 682 and 683 – introduction (section 683 defines the central concept of “income tax advantage”);
	Sections 684 and 685 – definition of the person liable to counteraction of income tax advantages;
	Sections 686 to 694 – circumstances in which, if income tax advantages are obtained or obtainable, the Chapter may apply;
	Sections 695 to 700 – procedure for counteraction of income tax advantages;
	Sections 701 to 703 – clearance procedure and information powers;
	Section 704 – how the special tribunal for the purposes of this Chapter is to be constituted;
	Sections 705 to 711 – appeals;
	Sections 712 and 713 – supplementary.