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) such 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.