Comparative Analysis of the United Kingdom Judicial Anti- Avoidance Rule and GAAR of Canada - Lesson for the UK from Canada
This article examines whether the current UK judicial approach is an adequacy of the judicial approach Rule of law and GAAR and studies the historical experience of Canada with its statutory solutions. Based on the comparative study background, the article considers to a large extent, a statutory general anti-avoidance principle might assist with the problems of statutory interpretation in the Uni