This article considers the effectiveness of the application of a general anti-avoidance rule (GAAR) when the impugned transaction or arrangement is cross-border. The vital issue is how a double tax agreement applies to the transaction or arrangement when the tax authorities invoke the GAAR.
CITATION STYLE
Elliffe, C., & Prebble, J. (2009). General Anti-Avoidance Rules and Double Tax Agreements: A New Zealand Perspective. Revenue Law Journal, 19(1). https://doi.org/10.53300/001c.6710
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