GAAR

News & Analysis as of

Italian Tax Reform

The Italian Government has recently approved a new decree, which reshapes the definition of abuse of law and tax avoidance and changes the rules on the statute of limitations in the event of tax crimes. The decree also...more

Italy Introduces New Rules to Increase Certainty of Tax Law

The Italian Government has finally approved the long-awaited act on “certainty of law in the relationships between tax authority and tax payers” (Certainty of Tax Law Act)....more

UK Summer Budget 2015 – Key Tax Measures

The Chancellor of the Exchequer’s first Budget of the new Parliament, delivered on 8 July 2015, will be remembered as a reforming Conservative budget, including significant changes to the United Kingdom’s welfare provisions...more

UK budget 2015

Earlier today the UK government delivered its last budget before the UK general election in May. Many of the measures were, as one might expect so close to an election, focused on personal rather than corporate taxation....more

Spruce Credit: Avoidance transactions and the Duke of Westminster

In Spruce Credit Union v. The Queen (2014 FCA 143) the Federal Court of Appeal upheld the lower court’s interpretation and application of the inter-corporate dividend deduction under subsection 112(1) of the Income Tax Act...more

International Tax News - October 2013

COLOMBIA ISSUES TAX HAVENS LIST: 4 THINGS TO NOTE FOR THOSE DOING BUSINESS IN COLOMBIA - Colombia has issued its list of tax havens – an act that will negatively impact the tax effects of doing business in Colombia...more

India: more certainty for investors, or less? Actions to take re the latest on GAAR, TP safe harbors, subsidiary PE

Recent legislative and case-law developments have clarified India’s position on a number of tax and transfer pricing issues. While many of these developments are intended to increase certainty for foreign investors, a number...more

Canada Revenue Agency Provides Update On Rulings And GAAR At Toronto Centre CRA & Professionals Group Breakfast Seminar

On June 6, 2013, at the Toronto Centre CRA & Professionals Breakfast Seminar, the Canada Revenue Agency discussed (a) recent developments at the Income Tax Rulings Directorate and (b) the process through which the General...more

The Gwartz Decision: The GAAR Is Not A Filler

In Brianne Gwartz v. The Queen, 2013 TCC 86, the Crown attempted to utilize the GAAR to recharacterize as dividends certain capital gains which had been realized by a family trust and allocated to the minor-aged taxpayers in...more

India Budget 2013: Key Changes Affecting International Investors

On February 28, 2013, India’s Finance Minister presented the country’s budget for the fiscal year beginning April 1, 2013 (Budget). The Budget includes several proposals that affect international investors investing in India,...more

Financial Services Tax – UK Update from Dechert’s Tax Group - February 2013: Get Ready for the GAAR

Draft clauses to introduce a new general anti-abuse rule (GAAR) into the UK tax code were published as part of the Finance Bill 2013 on 11 December 2012. Some form of general anti avoidance rule was first seriously canvassed...more

A Month in UK Employment Law - January 2013

In This Issue: - 2013 – What's On the Horizon - Changes Confirmed - Changes Expected In 2013 But No Implementation Date ...more

UK Tax Law Changes May Affect Fund Industry

Recently proposed changes in UK law could affect private investment funds that operate or have partners, employees or investments in the UK. Many of the proposed changes are included in the draft Finance Bill 2013, which was...more

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