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.
Elliffe, Craig and Prebble, John
"General Anti-Avoidance Rules and Double Tax Agreements: A New Zealand Perspective,"
Revenue Law Journal: Vol. 19
, Article 4.
Available at: http://epublications.bond.edu.au/rlj/vol19/iss1/4