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The relation between the legal form of transactions and their economic substance is a basic issue in tax law. Subject I explores and evaluates the attitudes taken by various jurisdictions, within income tax regimes. General and specific doctrines and rules on substance and form, tax avoidance and the use of civil law concepts in taxation are dealt with. Based on cases from important jurisdictions, the discussion focuses on their implications for tax planning in the context of legal security of the taxpayer, equity among taxpayers and efficiency in tax collection.