A paradox of the General Anti-Abuse Rule (GAAR) is that it is meant to be narrowly focussed, targeted at abusive tax avoidance schemes and yet some of the threshold tests – “one of the main purposes” and “tax arrangements” - could describe conventional everyday planning.
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The US president also unveiled a new 50% levy on copper imports; in other news, a UK wealth tax proposal has been criticised by the Institute of Fiscal Studies
MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process