There is a consensus that the introduction of a GAAR must be accompanied by a clearance mechanism. Rather than debating the pros and cons let’s assume that this happens.
What impact would it have on tax practitioners? I have been conducting a thought experiment imagining that a GAAR and clearance mechanism are already in place.
The vast majority of what comes across my desk would not I believe fall foul of a GAAR – it is straight-down-the-middle tax planning supporting genuine commercial activities of entrepreneurial clients.
