ConCourt ruling expands GAAR reach and raises investor risk
A wider interpretation of ‘party’ under GAAR means even commercially sound participants may face SARS’s scrutiny in multi-entity transactions.
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GAAR assessments cannot be rewritten in litigation, SCA rules
SARS cannot fundamentally alter the factual basis or remedy of an assessment issued under the general anti-avoidance rule provisions through a Rule 31 statement.
