
Anti-abuse clauses are the mechanism typically used by different jurisdictions to avoid “abuse of tax rules” in a business environment characterised by the growing numbers of cross-border transactions taking place. Clauses of this kind are gaining increasing importance internationally, triggering their implementation by countries which have traditionally been reluctant to impose them, their recasting by other countries, the issue by supra-national organisations such as the European Commission of recommendations for their adaption, and their interpretation by tax authorities in highly expansive...
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