The Polish GAAR is Just a GAAR! Why the Head of the National Revenue Administration Thinks Differently?
Inspiration, purpose and the context of this contribution In the article “The PPT in Post-BEPS Tax Treaty Law: It Is a GAAR but Just a GAAR!”, Professor Robert Danon convincingly demonstrated that “while the PPT certainly permits a purposive interpretation, it may not be used to build into tax treaty law additional requirements that were…