The UK General Anti-Avoidance Rule: Transplants and Lessons

Journal
Freedman, J.
European Union; OECD; United Kingdom
Bulletin for International Taxation 2019 (Volume 73), No. 6/7
FormatPDF
EUR
40
| USD
45 (VAT excl.)

The UK General Anti-Avoidance Rule has been criticized both for being too narrow and too wide. This article examines the origins of the UK GAAR, its wording and evolution, and the use of concepts and phrases transplanted from the United Kingdom and used in the European Union’s ATAD and BEPS Action 6.