This is the last in a series of four articles, in which the authors compare specific aspects of the real estate investment trust (REIT) regimes in the United States, the United Kingdom and Germany. Previous articles dealt separately with the REIT regimes in each of these countries. The United...

The English version of this paper can be found at: http://ssrn.com/abstract=1473612 The article compares the general anti-avoidance rule of income tax law with the civil law doctrine of abuse of law (Rechtsmissbrauch, abus de droit) in eight jurisdictions: Germany, Croatia, New Zealand,...