GTL Summary:

Article 26 establishes a general anti-avoidance rule (GAAR). It stipulates that the tax effects of any agreement or transaction shall be disregarded if it is proven that its primary objective is tax reduction, deferral, or exemption. For tax assessment purposes, the true commercial or economic substance of the transaction must be prioritised over its legal form. This ensures that arrangements are evaluated based on their substantive reality to counteract artificial schemes designed solely for tax benefits. The executive regulations are designated to further define the specific terms and conditions for the application of this article.