Abstract
This paper seeks to compare and contrast the Australian and New Zealand general anti-avoidance rules (GAAR) and to highlight what parts of each respective GAAR work well and which parts could be improved. The paper will first discuss what is meant by the term tax avoidance and then outline the current general anti-avoidance rules in New Zealand and Australia that are designed to counter tax avoidance. The paper will then compare the New Zealand GAAR as against the Australian GAAR.
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