The Tax Administration has released Administrative Jurisprudence No. 261/2017 on 3rd February 2017 on its website. This addresses for the first time a query regarding the application or non-application of the general anti-avoidance rule (GAAR) contained in articles 4 bis and following of the Tax Code. The question referred to whether article 4 bis was applicable to a situation in which a company is split up and the new company formed as a result is dissolved in order to allocate and attribute the assets in the hands of the shareholders. Under this query, the tax administration stated that the application or non-application of the GAAR to this situation should be addressed considering the specific circumstances of the case.
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