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May 15, 2026
This article introduces a broad General Anti-Abuse Rule (GAAR) to combat tax avoidance. The rule applies to any transaction or arrangement where it can be reasonably concluded that it lacks a valid commercial purpose and one of its main purposes is to obtain a Corporate Tax advantage inconsistent with the law's intent. If the GAAR is invoked, the Federal Tax Authority can counteract the advantage by issuing an assessment that may disallow deductions, recharacterise payments, or otherwise adjust the tax outcome to reflect the economic substance of the arrangement rather than its legal form.
Chapter 15 - Anti-Abuse Rules
Article 50 - General Anti-Abuse Rule
[GTL Notes]
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