GAAR - Trinidad & Tobago - Iatj.net

More documents

Recommendations

Info

SAAP in <strong>Trinidad</strong> & <strong>Tobago</strong> • Similarly worded provisions exist under S. 67 of the Income Tax Act in relation to dispositions to a minor (S.67(2) and transfer sof trust property. • S. 67(3) for example reads as follows: 3rd IATJ Assembly Munich 18‐19 October 2012 56
(3) Where a person transfers property in trust and provides that a corpus of the trust shall revert either to the donor or to such persons as he may determine at a future date, or where a trust provides that during the lifetime of the donor no disposition or other dealing with the trust property shall be made without the consent, written or otherwise, of the donor, such person shall nevertheless be liable to be taxed on the income derived from the property transferred in trust, or from property substituted therefor, as if such transfer had not been made. 3rd IATJ Assembly Munich 18‐19 October 2012 57
Page 1 and 2:
ANTHONY DJ GAFOOR TRINIDAD & TOBAGO
Page 3 and 4:
Topical nature of Anti‐Avoidance
Page 5 and 6: Distinguishing Tax Evasion, Avoidan
Page 7 and 8: Royal Commission on the Taxation of
Page 9 and 10: Review of Anti‐Avoidance principl
Page 11 and 12: Review of Anti‐Avoidance principl
Page 13 and 14: Common Law jurisdictions • Have i
Page 15 and 16: International tax evasion and avoid
Page 17 and 18: Hybrid developments • These may b
Page 19 and 20: Tax Treaties • Bilateral tax trea
Page 21 and 22: • However, for many developing co
Page 23 and 24: 3rd IATJ Assembly Munich 18‐19 Oc
Page 25 and 26: Revised Treaty of Chaguaramas • T
Page 27 and 28: Revised Treaty of Chaguaramas • I
Page 31 and 32: Treatment of anti‐avoidance in th
Page 33 and 34: Leading anti‐avoidance cases in t
Page 35 and 36: Jamaica and Barbados • These are
Page 37 and 38: GAAR in the Caribbean • Typically
Page 39 and 40: Artificial transactions • Artific
Page 43 and 44: Wide scope of the anti‐avoidance
Page 45 and 46: Wide scope of anti‐avoidance prov
Page 47 and 48: St. Lucia • It was argued by the
Page 49 and 50: Jamaica • The leading case from t
Page 51 and 52: Jamaica • The Privy Council held
Page 53 and 54: Consequences of invoking the genera
Page 55: Specific Anti‐Avoidance Provision
Page 61 and 62: Background • In 1980s‐1990s, a
Page 63 and 64: Arguments • The rhetorical contes
Page 65 and 66: Lessons to be learnt • The need f
Page 67 and 68: Closing thoughts • Adam Smith oft
show all

GAAR - Trinidad & Tobago - Iatj.net

You also want an ePaper? Increase the reach of your titles

Delete template?

Save as template?