GAAR and Tax Treaties

Tax avoidance, a concept increasingly familiar to most developed countries, has assumed dominant presence in international taxation. The subject was the focus of the International Fiscal Association’s (IFA) Seoul Congress in 2018, which focused on the use of the general anti-avoidance rule (GAAR) to combat avoidance. There is, however, no consensus between countries on what they mean by “tax avoidance” and the definitional challenges are substantial, which encourages conflicts that affect the movement of capital and services.

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