Gibraltar Strengthens Anti-Avoidance Rules

Gibraltar has published the Income Tax (Amendment) Act 2025, which strengthens the anti-avoidance rules under Section 40 of the Income Tax Act 2010 (the Act), which is replaced effective 11 July 2025. The new Section 40 provides that a tax avoidance arrangement is null and void against the Commissioner for the purposes of the Act. The Commissioner may counteract or disregard any tax advantage that a person has obtained from or under a tax avoidance arrangement. For this purpose:

• An "arrange…