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July 17, 2026
Article 100 reinforces the Tax Authority's anti-avoidance powers regarding asset disposals. It clarifies that while the Authority may approve a price apportionment agreed between parties, it must intervene if the agreement appears to provide an 'unjust tax advantage'. In such cases, the Authority is empowered to ignore the contractually agreed-upon split and reallocate the sale price or insurance proceeds between the various assets according to its own determination of their 'correct value'. This ensures that disposal values used for tax calculations—and subsequent balancing charges—reflect the true economic reality of the transaction.
Article 100
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