LE “GENERAL ANTI AVOIDANCE (ABUSE) RULES” IN ITALIA E NEL REGNO UNITO: UN’ANALISI COMPARATISTICA

The aim of this paper is the comparative analysis of the two General Anti Abuse Rules introduced, in 2013 and 2015 respectively, in Italy and the United Kingdom. For their chronological proximity, the two GAARs share the same international climate, but express only partially convergent choices and place themselves at different evolutionary stages. With regard to these rules, the development of evolutionary processes induced by the combination of endogenous and exogenous dynamics to individual national systems is frequently noted. A method specification: given the breadth of the comparison front, the main aspects of the two regulations will be selected, without pretense of comprehensiveness. Particular importance will be given to the legislative policy profiles, including in the historical-evolutionary dimension, and to the circulation of legal models.