A General Anti-Avoidance Rule (GAAR) is currently included in many tax systems to counteract the use (considered abusive) of the optimisation possibilities inherent in tax laws and available to taxpayers. A GAAR is applied if the sole or main purpose of the taxpayer's legal activity was avoiding taxation. Owing to its nature, the GAAR inevitably uses vague terms. Its structure always gives the tax authorities a large margin of discretion when making decisions. Therefore, even though the

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... s made by tax authorities are subject to judicial review, some countries operate the system in which the position is worked out by the tax administration with the participation of special consultative bodies appointed for that purpose.