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With the approval of the general norm of tax avoidance in the national tax laws, there are several judgments of the Administrative Council of Tax Appeals – Conselho Administrativo de Recursos Fiscais (CARF), which have used a tax avoidance institute of comparative law to consider specific practices resulting from companies' mergers, splits or amalgamation as abusive tax planning. It is known as the "business purpose doctrine", which has been running the Counselours of the CARF to establishdoi:10.17768/pbl.v3i3-4.34409 fatcat:an3h7fe2r5d4nd7orkhxp5gx6i