Aggressive tax planning (ATP) is a tax avoidance transaction that consists in reducing the effective tax rate applicable to a given source of income so that it is lower than the rate sought by the spirit of the law or provided for under the underlying fiscal policy.

Using ATP violates the principle that all taxpayers must contribute their fair share toward the funding of public services.

ATP includes:

• reducing, deferring or sheltering income and capital gains that should be reported 
• creating losses that would not otherwise exist 
• unduly claiming tax credits and exemptions