(2)The consequences of an arrangement declared to be an impermissible avoidance arrangement as referred to in sub-section (1) shall include but shall not be limited to the following:—(a)disregarding, combining or recharacterising any step in, or a part or whole of, the impermissible avoidance arrangement;(b)treating the impermissible avoidance arrangement as if it had not been entered into or carried out;(c)treating any disregarding any accommodating party or accommodating party and any other party as one and the same person;(d)deeming persons who are connected persons in relation to each other to be one and the same person for the purposes of determining tax treatment of any amount;(e)reallocating amongst the parties to the arrangement—(i)any accrual, or receipt, of a capital nature or revenue nature; or(ii)any expenditure, deduction, relief or rebate;(f)treating—(i)the place of residence of any party to the arrangement; or(ii)the situs of an asset or of a transaction,at a place other than the place of residence, location of the asset or location of the transaction as provided under the arrangement; or(g)considering or looking through any arrangement by disregarding any corporate structure.
