When Is a SAAR Not a SAAR? When It’s a GAAR

Countries have long employed a variety of tools to address artificial arrangements designed to avoid taxation, including specific anti-avoidance rules (SAARs) and general anti-avoidance rules (GAARs). While these might appear to be mutually exclusive, that is not always the case. In the latest Talking Points, Shruti Lohia reviews a case making its way through the Indian courts, which asks whether an arrangement that does not violate a SAAR may still run afoul of that country’s GAAR. So far, the answer is yes.