This article considers several issues that make the application of Part IVA uncertain and whether recent tax office guidance, in the form of PS LA 2005/24 and the Guide, provide any further clarity on these issues. It is suggested that PS LA 2005/24 and the Guide fail to provide further clarity and this is largely due to the fundamental problem that it is unclear what particular activities Part IVA seeks to target at a policy level. Consequently, Part IVA has been drafted in a manner that is amorphous and uncertain in order to combat these indeterminate activities.
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Paper provided by ATAX, University of New South Wales in its series Taxation with number
eJournal of Tax Research Vol 4 No. 1.