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May 15, 2026

Part 4 - Avoidance of Double Taxation

Chapter 2 - Tax Avoidance between Persons or By Entering into Transactions

Section 2 - Cases of Avoidance by Entering into Transactions

Article 129

[GTL Notes: Tax Avoidance Transactions]

The provisions of this Section shall apply if it is established by the Authority that the main purpose of any transaction made whether before or after the date on which this Law takes effect - is to avoid part or whole of any liability to tax due and payable for any tax year.

The transaction is considered to have achieved that purpose if the partial or whole avoidance is obtained through the combined effect of two or more transactions, or through the combined effect of one or more transactions concurrent with the dissolution of the company.