For purposes of this Part –

 

‘arrangement’ means any transaction, operation, scheme, agreement or understanding (whether enforceable or not), including all steps therein or parts thereof, and includes any of the foregoing involving the alienation of property;

‘avoidance arrangement’ means any arrangement that, but for this Part, results in a tax benefit;

‘impermissible avoidance arrangement’ means any avoidance arrangement described in section 80A;

‘party’ means any –

 

(a)     person;

 

(b)     permanent establishment in the Republic of a person who is not a resident;

 

(c)     permanent establishment outside the Republic of a person who is a resident;

 

(d)     partnership; or

 

(e)     joint venture,

 

who participates or takes part in an arrangement;

‘tax’ includes any tax, levy or duty imposed by this Act or any other Act administered by the Commissioner;