The Australian Taxation Office’s (ATO) response to the High Court’s judgment in the Mills case, where the taxpayer escaped the general anti-avoidance rule (GAAR), shows an acceptance the ruling is not limited to tier one capital raising by banks. The response could also help taxpayers outlining GAAR defences in future litigation.
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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties