The Belgian program law of March 29, 2012 has replaced the general anti avoidance rule by an anti abuse rule. The GAAR was introduced in the income tax, registration tax, and inheritance tax codes in 1993 but had proven ineffective. The new rule must combat abuses of tax avoidance schemes, but even after Finance Minister Steven Vanackere published a first practice note, there was a demand for some examples of transactions that the tax authorities considered abusive tax avoidance.
On July 19, the tax authorities published a second practice note that gave a list of examples regarding the inheritance tax and registration tax (read the full article).
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