Treatment of connected person and accommodating party
Treatment of connected person and accommodating party.
99. For the purposes of this Chapter, in determining whether a tax benefit exists,—
| (i) | the parties who are connected persons in relation to each other may be treated as one and the same person; | |
| (ii) | any accommodating party may be disregarded; | |
| (iii) | the accommodating party and any other party may be treated as one and the same person; | |
| (iv) | the arrangement may be considered or looked through by disregarding any corporate structure. |