Cap. 123 · Income Tax Act (Cap. 123)
Cap. 123 Art. 95Anti-avoidance provisions.
PART X
Where, in the opinion of the Commissioner, a series of transactions is effected with the sole or main purpose of reducing the amount of tax payable by any person by reason of the operation of the flat-rate foreign tax credit provisions as contained in articles 92 to 94, such a person shall be assessable as if the provisions did not apply. For the purposes of this article, a series of transactions shall mean any two or more corresponding or circular transactions carried out by the same person, either directly or indirectly, as the case may be.