4.4. Ability to disregard or recharacterize transactions


Rubén Marchevsky and Pablo Porporatto
lectronic document
Spanish and English
 CIAT 2023

Contents note:

The CIAT Executive Secretariat invites you to download and read chapter 4.4. ‘Ability to disregard or recharacterize transactions’  of the Manual for the Control of International Tax Planning written by Rubén Marchevsky and Pablo Porporatto.

Through this section, the authors disclose useful tools to grant the tax authority the ability to ignore or recharacterize transactions, international experiences, and recommendations to make efficient and effective use of said powers.

Among the critical aspects dealt with are; reflections on the autonomous will of the taxpayer and its limits, comments on the design of model regulations to implement these powers, issues related to the recommendations of the BEPS Action Plan and other practical issues related to General Anti-Abuse Rules.

This section was written by Dr. Marchevsky when he was exercising the Presidency of the Fiscal Court of the Argentina, in collaboration with Pablo Porporatto, current Judge of the same Court; shortly before his death. That is why with this publication we want to honor Dr. Marchevsky for his human quality, professional career, generosity and contribution to the tax community.

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