Schedule 4 Avoidance involving profit fragmentation arrangements

1. Introduction and overview
2. Profit fragmentation arrangements
3. Transfer of value deriving directly or indirectly from a business
4. The enjoyment conditions
5. Tax mismatch
6. Tax mismatch: resulting reduction and resulting increase
7. Adjustments required to be made in relation to arrangements
8. Double taxation
9. Reimbursement payments ignored for tax purposes
10. Treatment of a person who is a member of a partnership
11. Other defined terms
12. Commencement