To overcome these limitations Part IVA was introduced to cancel a tax benefit where it could be objectively concluded that an arrangement was entered into the sole or dominant purpose of obtaining a tax deduction or having an amount left out of assessable income. Essentially, the Commissioner of Taxation has much more flexibility in applying Part IVA than under the former antiavoidance provisions set out in section 260. To ensure that Part IVA was effective section 1773(1) provides that Part IVA has paramount force and takes priority over other provisions contained in the ITAA [1936] and ITAA [1997) other than for a minor exception available to primary producers. It is also important to note that the provisions of Part IVA have been amended on several occasions particularly in the 2013 and 2015 years where it scope has been considerably expanded as set out in the commentary below. We will now consider the 4 key elements that must be satisfied in order for the general antiavoidance provisions of Part IVA to apply to cancel a tax benefit derived under a tax avoidance scheme. Elements of Part IVA For Part IVA to apply the Commissioner of Taxation must: 0 Identify whether there is a 'scheme' to which Part IVA could potentially apply as that term is defined under section EVA; 0 Determine whether the relevant taxpayer has obtained a \"tax benefit' under that scheme based on the concept of tax benefit set out in sections 177C and INCH; 0 Conclude that a person entered into the scheme for the 'purpose' of allowing the relevant taxpayer to obtain a tax benefit under the scheme bearing in mind the matters listed in section 177Dl2); and 0 Determine to cancel any tax benefit that has arisen under the above steps under section 177E In practice, the first three ofthese steps are often very complicated to apply especially in areas of the income tax law which are uncertain. This complexity is further compounded by the fact that the above 3 tests are to a large degree interdependent. We will therefore now look at each of the above elements of Part lVi in further detail. Scheme The first step is to identify whether there is a scheme to which Part IVA could potentially apply. The term 'scheme' is defined under section 17?A(1) to mean: {a} any agreement, arrangement, understanding, promise or undertaking, whether express or implied and whether or not enforceable, or intended to be enforceable, by legal proceedings; and lb) any scheme, plan, proposal, action, course of action or course of conduct. As will be evident from the above definition the term scheme is very broad in nature and can potentially capture most transactions entered into by taxpayers