Clifford Chance

What transactions are intended to fall within the scope of the GAAR?

11 April 2012

Unfortunately the Aaronson Report does not give examples of arrangements that would be caught by the GAAR, perhaps because most aggressive tax planning has failed in the courts recently. Even where taxpayers have steered a course through the maze of anti-avoidance legislation, the courts have taken purposive approaches which deny the intended tax benefits.

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