Adopting mandatory disclosure tules of tax systems of general anti-abuse rules exists where tax audit practices are stringent just only may deteriorate the position of the taxpayers by imposing extra burden and coercive measure.
Adopting mandatory disclosure rules in tax systems where general anti-abuse rules (GAAR) provisions do exist and where tax audit practices are stringent may only deteriorate the position of the taxpayers by imposing an extra burden and coercive measure.