INTM610140 - Exception Conditions

Arrangements are not Profit Fragmentation Arrangements if either of the two Exception Conditions is met. »Ê¹ÚÌåÓýappse are:

  • »Ê¹ÚÌåÓýapp Tax Mismatch Condition, and
  • »Ê¹ÚÌåÓýapp Tax Advantage Condition.

»Ê¹ÚÌåÓýapp existence of a tax mismatch, or of a tax advantage purpose, will not in itself mean that the arrangements are Profit Fragmentation Arrangements. It is always necessary to consider the interaction between all of the conditions and exception tests before applying any adjustment.