GAAR AS TAX TREATY OVERRIDE – SLOVAK PERSPECTIVE
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Paper by: Guillermo O. Teijeiro Most countries have either judicial or statutory general anti-avoidance rules (GAAR); Argentina enrols in the second group as GAAR are
The ability of some countries to unilaterally change, or “override,” their tax treaties through domestic legislation has frequently been identified as a serious threat to
DTC are binding agreements between usually two States and thus are governed by Public International Law. In the majority of jurisdictions, the introduction of DTC
The decisions of recent Australian case law relating to the general anti-avoidance regime was cause for concern among the Australian tax community, as the Assistant
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