Rule 127 says that where only part of an arrangement is declared an impermissible avoidance arrangement, the tax consequences are determined with reference to that part only.
127
Rules 2026 · Rule 127
Determination of consequences of impermissible avoidance arrangement
Rules 77-130
The rule. For section 181, where a part of an arrangement is declared to be an impermissible avoidance arrangement, the consequences in relation to tax are determined with reference to that part only.