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2. Definitions for applying the General Anti-circumvention Standard

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For purposes of Supreme Decree No. 145-2019-EF, the following is defined as:

General Anti-avoidance Rule: the standard contained in the second to fifth paragraphs of Standard XVI of the Preliminary Title of the Tax Code.

Tax savings or advantages: to the total or partial reduction of the tax debt; to the reduction or elimination of the taxable base; to postpone or defer the tax liability or tax debt; to obtaining credit balances, credits, refunds or offsets, tax losses or tax credits; to obtain tax immunity, tax exemption, non-taxation, exemption

or tax benefit; to be subject to a special tax regime; to any situation that causes the person or entity to cease to be subject to or to reduce or postpone its tax liability or the payment of taxes.

Tax planning strategy: The action of choosing and the result of choosing to carry out acts that are less onerous in tax terms than others possible or available in the legal system and in respect of which none of the circumstances set forth in subsections a) and b) of the third paragraph of Standard XVI of the Preliminary Title of the Tax Code are present.