4.2. Specific anti avoidance rules: domestic and international


Jacqueline Vargas
lectronic document
Spanish and English
CIAT May 2022

Contents note:

The CIAT Executive Secretariat is pleased to present a new chapter of the Manual for the Control of International Tax Planning, prepared by Ms. Jacqueline Vargas, which addresses aspects related to specific anti-avoidance rules for domestic and international operations. Among other issues, the section develops matters related to the limitation to the deduction of expenses, the presumption of income, the undue transmission of losses, the definition of the concept of “Tax Residence”, the definition of the concept of “Ultimate Beneficiary” and elements to be considered to define the existence of a “Permanent Establishment”. Additionally, the author provides reflections on the effectiveness of these rules and opportunities to improve them.

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