On December 27, 2022, the Administrative Tax Rules (“ATR”) for 2023 were published on the Official Federal Gazette, in which rule 2.1.52 was included, addressing the integration of the Collegiate Body empowered to approve the application of the domestic General Anti-Avoidance Rule set forth in article 5-A of the Federal Tax Code (“GAAR”).
The GAAR was introduced to the tax legal framework in 2020, according with the explanatory memorandum of the Federal Tax Code, with the purpose of eliminating the inequity generated by taxpayers who execute legal transactions to configurate operations that lack a business reason and that have the sole objective of generating a more advantageous tax position.
