Gibraltar gay rule 342/1/2024 ![]() There is also a specific rule in relation to interest payments. The general anti-avoidance rule in the Income Tax Act should be interpreted in such manner as best secures consistency with the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and other documents designated as comprising part of the transfer pricing guidelines. Where a taxpayer seeks to reduce their liability to tax by creating an artificial split between activities in Gibraltar and outside of Gibraltar, the Commissioner shall use anti-avoidance provisions to defeat such an attempt. ![]() In addition, it includes the following specific anti-avoidance measures. The Income Tax Act contains a generic anti-avoidance clause that allows the Commissioner to disregard an arrangement that the Commissioner believes is fictitious or artificial. Companies are assessed on an individual basis, and trading losses of group members may not be offset against profits of other members of the group.
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