Session Details Page | International Bar Association

IBA Annual Conference Copenhagen 2026

4 Oct - 9 Oct 2026

Session information

What are the GAARdrails?

Monday 5 October (1600 - 1730)

Committee(s)

Taxes Committee (Lead)

Description

Panellists will discuss how courts and tax authorities have applied or attempted to apply anti-avoidance rules, whether in the form of a domestic GAAR, the principal purpose test (PPT), treaty-embedded SAARs, or the beneficial ownership test, to deny treaty or EU Directive benefits. The discussion will explore the similarities and differences among these approaches and consider the point at which taxpayers appear to be falling over the anti-avoidance tax cliff.

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