(1) If a person is a
party to a tax-reducing arrangement, the Commissioner may —
(a)
disregard the arrangement;
(b)
determine that any party to the arrangement is an employer for the purposes of
this Act; and
(c)
determine that any payment made under the arrangement is wages for the
purposes of this Act.
(2) If the
Commissioner makes a determination, he or she must —
(a)
serve a notice to that effect on the person; and
(b) set
out in the notice the grounds on which the Commissioner relies and his or her
reasons for making the determination.