This article examines whether the general anti-avoidance rules of New Zealand, Australia and Canada achieve results similar to the UK's judicial approach to tax avoidance. The article also considers whether one approach is superior to the other. The article develops these issues by examining the role played by a general anti-avoidance rule in New Zealand, Australia and Canada and contrasts that with the absence of a similar statutory rule in the United Kingdom. The article concludes that, although there is significant convergence between the approaches taken by the courts in New Zealand, Canada and the United Kingdom, a general anti-avoidance rule provides a statutory framework for judicial decision-making which is preferable to the development of judicial anti-avoidance doctrines in the United Kingdom.