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12.1. GAAR and General Anti-Avoidance Measures

Domestic laws do not include any specific provisions against tax havens. On 1 June 2014, the Egyptian government introduced a general anti-avoidance rule, whereby the tax authorities may disregard a transaction if its main purpose, or one of its main purposes, is to avoid or defer tax. When evaluating a transaction under GAAR, while the burden of proof is on the tax authorities to determine that a particular transaction’s main purpose is tax avoidance, however, the taxpayers are also required to provide adequate proof that the transaction is not entered into with the main purpose of deriving tax benefits.

Domestic laws do not override tax treaties.