Manual for the Control of International Tax Planning – Chapter 4.2. Specific anti-avoidance rules

Author: Jacqueline Vargas.

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.

Jacqueline Vargas is a Mexican national with a degree in Economics from the Instituto Tecnologico Autónomo of Mexico, with a Master of Arts in Economics from the Catholic University of Louvain, Louvain-la-Neuve, Belgium, and a certificate in International Taxation from Duke University and the Instituto Tecnologico Autónomo de México.

This chapter, available in English and Spanish, is the third document published within the framework of the Manual for the Control of International Tax Planning prepared by CIAT with the support of GIZ (German Cooperation) and EUROsociAL+. Its Chapter 1, “Introduction, Scope and Objectives” and Chapter 2 “International Tax Planning” was published in April 2022. The Manual has 6 sections segmented into 42 chapters, which will be published over the next few months.


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