This chapter provides a brief overview of the different approaches that countries pursue with regard to the concept of tax avoidance. It begins by defining tax evasion, tax avoidance, and licit tax savings. It then analyzes the differences between civil law and common law countries in their approach to tax avoidance. It compares the “substance-over-form” doctrines (typical of common law countries) with the “general anti-abuse” doctrines (typical of civil law countries).
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