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Podcast: Offshore Tax with HTJ.tax
Episode: Cyprus - GAAR: Capturing Non-Genuine Transactions
Description: In this episode, we explore the General Anti-Abuse Rule (GAAR) introduced in Cyprus under the EU’s Anti-Tax Avoidance Directive (ATAD). The GAAR serves as a broad safeguard against aggressive tax planning that may fall outside specific anti-avoidance rules like transfer pricing, CFC, or interest limitation provisions.We break down how Cyprus applies the GAAR to non-genuine arrangements, what counts as “economic reality,” and how the rule fits into the broader international move toward substance-based taxation.⚖️ The Rule in FocusUnder the Cyprus GAAR, any arrangement or series of arrangements that:<...