Comparison of the Substantive Aspects of Impermissible Tax Arrangements in South Africa’s General Anti-Avoidance Rule and the Principal Purpose Test in the OECD Model (2017)

Abstract

This article compares the substantive aspects of impermissible tax arrangements in the South African general anti-avoidance rule and the Principal Purpose Test set out in article 29 of the OECD Model (2017), with emphasis on an evaluation of the examples in the Commentary on Article 29 of the OECD Model (2017).