THREADBrowse · 7 entries, read in order

Tax avoidance

Where planning ends and avoidance begins, from McDowell to Vodafone and the retrospective amendment.

01
Encyclopedia · Concept
Tax Avoidance
The line between planning, avoidance and evasion in Indian tax law, from the Westminster principle to the general anti-avoidance rule.
Wanted
02
Encyclopedia · Doctrine
Substance over Form
When revenue authorities may disregard the legal form of a transaction, and the "look at" approach that restrains them.
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03
Review · Lineage
Tax Planning, from McDowell to Vodafone
The reception of Ramsay in India, the retreat in Azadi Bachao, and the reconciliation attempted in Vodafone.
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04
Review · Dissent
Chinnappa Reddy J. in McDowell
A concurring opinion that went further than the majority in condemning tax avoidance, and its long afterlife.
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05
Review · Dissent
Radhakrishnan J. in Vodafone
A concurring opinion with its own account of holding structures and the limits of looking through them.
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06
Review · Lineage
Retrospective Taxation, from Vodafone to the 2021 Repeal
A Supreme Court ruling, an amendment reaching back to 1962, two treaty awards against India, and withdrawal.
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07
Proposals · Transplant
An Independent Panel before Anti-Avoidance Rules Are Invoked
The United Kingdom requires an outside panel’s opinion before its general anti-abuse rule is applied.
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