Article 131 bis 1 targets arrangements designed to evade administrative and legal duties. If the Tax Authority finds that the primary objective of a transaction or arrangement is to avoid compliance with any obligations imposed by the Income Tax Law (such as reporting or record-keeping), the Authority has the right to deem those arrangements 'inconsequential'. Effectively, the Authority can ignore the artificial structure and enforce the statutory obligations as if the avoidance arrangement did not exist. This ensures that the operational and oversight functions of the tax system cannot be bypassed through clever structuring.
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 131 bis 1
[GTL Notes: Avoidance of Obligations]
If it becomes apparent to the Authority that the primary objective of any arrangements or transactions is to avoid compliance with the obligations imposed in accordance with the provisions of this Law, the Authority has the right to deem those arrangements and transactions inconsequential.
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