Anti-avoidance remains a key focus area in the international tax landscape, with recent case law developments, proposed changes to Part IVA and the growing relevance of treaty-based provisions continuing to reshape the risk environment for cross-border arrangements. These developments are becoming increasingly important for multinational groups, investors and advisers managing international structures and transactions.
This session examined recent anti-avoidance developments in an international tax context, including proposed amendments to Part IVA and the practical application of treaty-based anti-avoidance provisions. It also considered the broader implications for structuring, governance and dispute risk in a rapidly evolving international tax environment.