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Section 33

Purpose or Effect
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The “Purpose or Effect” Test

Following the leading Court of Appeal case of CIT v AQQ [2014] SGCA 15 on the anti-avoidance section 33 of the Income Tax Act (ITA), we have the Income Tax Board of Review case of GBF v The Comptroller of Income Tax [2016] SGITBR 1, where section 33 was successfully invoked against the taxpayer.

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