Further to the decision of the Income Tax Board of Review (ITBR) in the case of AQQ v. The Comptroller of Income Tax ([2011] SGITBR1), the High Court decision has become available.

The main issues before the High Court were whether the ITBR had applied the correct approach in applying section 33 of the Income Tax Act (ITA) (the general anti-avoidance rule (GAAR)),…

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