(1) Subsection (2) applies where a person

(a) indirectly benefits from a payment; or

(b) directs that another person is to be the payee of a payment and the payer intends the payment to benefit the person who gave the directive.

(2) Where subsection (1) applies, the Commissioner-General may, by practice note or by notice in writing served on the person,

(a) treat that person as the payee of the payment;

(b) treat that person as the payer of the payment; or

(c) treat the person as the payee of the payment and as making an equal payment to the person who would be considered the payee of the payment if this subsection were ignored.

(3) In this section, an intention of the payer of a payment includes

(a) an intention of an associate of the payer; or

(b) a third person under an arrangement

(i) with the payer; or

(ii) with an associate of the payer.