Applicability of the Domestic General Anti-Avoidance Rule to Concluded Tax Treaties

In this article, the authors discuss the issue of whether Singapore’s general anti-avoidance rule (GAAR) can apply to a Singaporean tax treaty where there is no express anti-avoidance rule or reservation to apply the GAAR. It also covers the decision of the Income Tax Board of Review in the first anti-avoidance case in Singapore, AQQ v. CIT.