Factors that limit the efficacy of general anti-avoidance rules in income tax legislation : lessons from South Africa, Australia, and Canada
Why this work is in the frame
A frame that forgets how it found something cannot be audited. These are the routes that admitted this work.
Bibliographic record
Abstract
General anti-avoidance rules (GAARs) are rules in income tax legislation \nintended to curtail impermissible tax avoidance. GAARs have another \ncritical function, namely informing taxpayers of the limits of permissible tax \navoidance. A GAAR is therefore an important provision which must be \neffective. A study of the historical and current experience with GAARs in \nSouth Africa, Canada, and Australia, however, shows that the efficacy of \nGAARs is limited. The GAARs of the countries studied show some \nsimilarities but also some fundamental differences. In spite of these \ndifferences, certain common factors working against the efficacy of these \nGAARs can be identified. It is argued that these factors entail the inherent \nweakness of GAARs, controversial indicators of impermissible tax \navoidance, uncertainty, the role of the judiciary, taxpayer aggression, and \nthe limitations of the law as a weapon against impermissible tax avoidance. \nAdmittedly, some of these limiting factors are difficult to overcome. For \ninstance, a precise definition of impermissible tax avoidance has proved \nelusive and this status quo is likely to persist. Nevertheless, it is argued that \nthese factors need to be acknowledged and addressed in order to create more \neffective GAARs in future.
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Full frame distilled prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.000 | 0.000 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.000 | 0.000 |
| Science and technology studies | 0.000 | 0.000 |
| Scholarly communication | 0.000 | 0.001 |
| Open science | 0.000 | 0.000 |
| Research integrity | 0.000 | 0.000 |
| Insufficient payload (model declined to judge) | 0.000 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it