“The proposed General Anti-Avoidance Rule [UK] [...] attacks arrangements with one or more of these qualities:
(a) arrangements that would result in receipts being taken into account for tax purposes which are significantly less than the true economic income, profit or gain;
(b) arrangements that would result in deductions being taken into account for tax purposes which are significantly greater than the true economic cost or loss;
(c) arrangements that includes a transaction at a value significantly different from market value, or otherwise on non-commercial terms;
(d) arrangements, or any element of it, inconsistent with the legal duties of the parties to it;
(e) arrangements including a person, a transaction, a document or significant terms in a document, which would not be included if the arrangement were not designed to achieve an abusive tax result;
(f) arrangements that omit a person, a transaction, a document or significant terms in a document, which would not be omitted if the arrangement were not designed to achieve an abusive tax result; and
(g) arrangements that include the location of an asset or a transaction, or of the place of residence of a person, which would not be so located if the arrangement were not designed to achieve an abusive tax result.” http://www.taxresearch.org.uk/Blog/2011/11/21/making-aggressive-tax-avoidance-illegal-what-a-new-gaar-might-do/
