UK: HMRC publishes GAAR opinions on employee benefit trust IHT arrangements
UK’s His Majesty's Revenue and Customs (HMRC) has published two reports from the General Anti-Avoidance Rule (GAAR) Advisory Panel concluding that arrangements designed to reduce Inheritance Tax (IHT) through the use of employee benefit trusts
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South Africa: Tax Court upholds GAAR challenge to dividend stripping scheme
The South African Revenue Service (SARS) has published a South African Tax Court judgment upholding the application of the general anti-avoidance rule (GAAR) in a case involving shareholders of an investment company on 7 July 2026. The South
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Peru: SUNAT updates GAAR high tax risk scheme catalogue with 11 new arrangements
Peru's National Superintendency of Customs and Tax Administration (SUNAT) has published Version 4.0 of its Catalogue of High Tax Risk Schemes, adding 11 new arrangements that could be used to obtain undue tax benefits and may be challenged under the
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European Commission releases final report on ATAD evaluation
The European Commission has published its final evaluation report on the Anti-Tax Avoidance Directive (ATAD) on 25 June 2026, covering the period from 1 January 2019 to mid-2025. The report assesses the effectiveness of ATAD in meeting its
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South Africa: Constitutional Court dismisses ABSA appeal, upholds tax avoidance recharacterisation
The Constitutional Court of South Africa has dismissed the appeal in Absa Bank Ltd and Another v CSARS (CCT 72/24), a case concerning a ZAR 1.9 billion structured investment scheme, in a judgment delivered on 22 April 2026. The dispute involved
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Montenegro proposes draft corporate tax rules in accordance to EU ATAD
The Government of Montenegro has released a draft law on Amendments to the Law on Corporate Income Tax, proposing measures to address profit shifting in accordance with the EU Anti-Tax Avoidance Directive (ATAD) (Directive 2016/1164 as amended by
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India: CBDT grants GAAR (general anti-avoidance rule) relief for pre-April 2017 investments
India’s Central Board of Direct Taxes (CBDT) has released Notification 54/2026 and Notification 55/2026, introducing amendments to the Income Tax Rules, 1962 and 2026, concerning the application of the general anti-avoidance rule (GAAR) on income
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Poland: MoF consults functioning of General Anti-Tax Avoidance clause under Administrative Tax Code
Interested parties can submit their opinions by 8 October 2025. Poland’s Ministry of Finance and Economy has initiated a public consultation to evaluate the General Anti-Tax Avoidance (GAAR) clause, which was introduced in 2016 under the
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Ireland: Revenue issues guidance on general anti-avoidance rule and protective notifications
Irish Revenue has published eBrief No. 085/25 on 16 April 2025, introducing a new Tax and Duty Manual Part 33-02-03, which offers guidance on the general anti-avoidance rule and the use of protective notifications. This manual provides guidance
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Italy: Finance department clarifies general anti-avoidance rule
Italy’s finance department has issued guidelines on applying the general anti-avoidance rule (GAAR) under article 10-bis of Law No. 212 of 27 July 2000 on 27 February 2025. The document outlines the abuse of law doctrine and examines the key
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Chile updates tax compliance law, introduces changes to GAAR, transfer pricing, and CFC
Chile's Internal Revenue Service (SII) has announced that the Law on Compliance with Tax Obligations (Law No. 21.713) has been published in the Official Gazette on 24 October 2024. General and Special Anti-Avoidance Rules changes The General
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Chile: Parliament passes tax compliance bill
Chile’s Chamber of Deputies have passed the Tax Compliance Bill (Proyecto de Ley de Cumplimiento de las Obligaciones Tributarias). Earlier, Chile’s Senate approved the Tax Compliance Bill on 24 September 2024 which included key changes to
See MoreIreland named amongst top 10 tax havens globally
According to the Tax Justice Network's latest ranking report published on 1 October 2024, Ireland has surpassed the Bahamas to become the ninth-largest tax haven in the world. A spokesperson for Ireland's Department of Finance has denied that the
See MoreChile passes tax compliance bill with income, VAT, transfer pricing measures
Chile’s Senate has approved the Tax Compliance Bill on 24 September 2024, which will be presented to the Lower House for final approval. The newly approved tax measures include modifications to the general anti-avoidance rule (GAAR), statute of
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Peru releases third version of high-risk tax schemes catalogue under GAAR
Peru tax authority (SUNAT) has published the third version of its catalogue of high tax risk schemes that could be challenged under the country's General Anti-Avoidance Rule (GAAR). This updated list includes 11 new high-risk schemes, bringing the
See MoreChile passes tax compliance bill with updated GAAR rules
On 10 April 2024, Chile's Chamber of Deputies passed the Tax Compliance Bill, which includes numerous tax measures aimed at improving tax compliance in Chile. The newly approved Bill also changes the Chilean tax code. The Senate must approve the
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Singapore: IRAS updates e-Tax Guide on the general anti-avoidance provision and its application
On 31 Mar 2023, the Inland Revenue Authority of Singapore (IRAS) published the second edition of its e-Tax Guide concerning The General Anti-Avoidance Provision and its Application. The updated guide includes the following main purposes: First,
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Peru: SUNAT updates the list of high-risk tax planning schemes regarding GAAR
On 11 October 2022, the Peruvian Tax Administration (SUNAT) published second version of the list of high-risk tax planning schemes regarding the General Anti-Avoidance Rule (GAAR). The updated list contains the following thirteen tax planning
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