defeatist
发表于 2025-3-26 23:43:49
http://reply.papertrans.cn/15/1403/140286/140286_31.png
amnesia
发表于 2025-3-27 04:44:45
Michael D. Kickmeier-Rust,Dietrich Albertdded in the German Constitution, dictating that all taxpayers pay their share of taxes in accordance with ability to pay, is disrupted when taxpayers are permitted to circumvent this obligation by entering abusive arrangements. A new GAAR was adopted in 2008 in order to provide a more effective defi
CHASM
发表于 2025-3-27 05:42:29
Xingwei Hao,Xiangxu Meng,Xu Cuiwith the purpose of the legal rule. More particularly, Hungary has codified a GAAR, the first among the Middle-Eastern-European countries. The GAAR provides for: classification of a transaction in conformity with its real content, adherence to proper legal practice, reference to rules of connected t
cunning
发表于 2025-3-27 12:37:04
Paulo Quaresma,Irene Pimenta Rodriguese existence of a tax avoidance motive does not have any legal consequence. The court merely determines in a factual inquiry whether a given transaction involves impermissible tax avoidance. Although there is no GAAR, the legislature has enacted numerous TAARs. In particular, these rules target tax a
fatuity
发表于 2025-3-27 15:07:53
Alexander Gelbukh,Igor A. Bolshakovch the taxpayer claimed a tax reduction by circumventing the law to enter a transaction substantially similar to one in which another taxpayer bore a higher tax burden. A parallel rule, fraus legis, which was resurrected in the mid-1980s, has diminished reliance upon the GAAR. The taxing authority m
plasma
发表于 2025-3-27 19:10:36
http://reply.papertrans.cn/15/1403/140286/140286_36.png
PLUMP
发表于 2025-3-27 22:40:33
Advances in Web Intelligence and Data Miningosition to the notion of an anti-avoidance rule. When Poland began to move to a market economy in the early 1990s, the legislature made unsuccessful attempts to adopt a GAAR. Attempts by the courts to employ a judicial anti-avoidance rule were overturned by the Supreme Administrative Court. Enactmen
Synthesize
发表于 2025-3-28 05:39:55
Prasanna Desikan,Jaideep Srivastavality ordinarily due. This provision is applied by the tax administrator on a case-by-case basis. In addition, anti-avoidance case law from the European Court of Justice furnishes some guidance for addressing artificial tax arrangements. These rules have been implemented by incorporation of EU direct
GUMP
发表于 2025-3-28 07:29:19
http://reply.papertrans.cn/15/1403/140286/140286_39.png
宿醉
发表于 2025-3-28 14:06:15
Olfa Nasraoui,Myra Spiliopoulou,Brij Masandthe new approach that developed in 1980s case law. That approach employed a type of substance over form or step transaction analysis that allowed the courts to ignore steps taken without a commercial purpose in order to gain a tax advantage. In recent years the courts have denied the existence of a