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cf: ChristianAid declared victory (by fudging terms) in campaign to get local councils to adopt tax criteria https://medium.com/christian-aid-campaigns/sourced-campaign-our-work-is-done-91f0be03876 …
i.e. can be excluded if in breach of its obligations (i.e. by GAAR/ Halifax, DOTAS standards) but not for 'avoidance' as commonly spoken
Yup - they conceded standards had to be objective to avoid a dangerous level of subjectivity. But that eliminates much perceived avoidance.
I can't say for the UK debate, but in DK the emphasis has been on tax transparency requirements rather than substantive planning demands..
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