1. INTRODUCTION/BACKGROUND 1.1. The Supreme Court of India2 defined ‘tax avoidance’ as ‘the art of dodging tax without breaking the law’. The tax avoidance causes significant loss to the coffers of exchequers and hence, in last few years, the countries have become more vigilant about the tax avoidance practices adopted by the taxpayers. 1.2. In addition to Specific Anti-avoidance Rules (‘SAAR’), India has integrated General Anti- avoidance Rules (‘GAAR’) as a part of its taxing statue since April 2017. The implementation of the law is at a nascent stage and action on the ground is yet to take off. However, implementation of the GAAR provisions in overseas jurisdictions may help in shaping the law and the mindset of concerned parties. 1.3. Recently, the Court of Cessation (the Supreme Court) of Belgium has passed a judgment to uphold anti-abuse provisions against a taxpayer despit.......