LCITALaw for the Coordination of International Tax Affairs
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References in periodicals archive ?
This also holds true for the proposed codification of the substance-over-form rule in the Law for Coordination of International Tax Affairs (LCITA).
In this sense, it can be safely said that even if a provision on the rule is inserted in the LCITA as proposed this year, it will be only a declaratory and confirmatory provision.
In other words, taxation on such transactions will be determined in accordance with the previous court decisions and extended interpretation of relevant provisions on the substance-over-form principle in the Basic Law for National Taxes and the Corporation Tax Law, while taxation on those transactions to be made after the new provision in the LCITA takes into effect will be determined pursuant to the substance-over-form principle based on that particular provision.