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Full-Text Articles in Law
International Tax: Tax Treaties, Kim Brooks
International Tax: Tax Treaties, Kim Brooks
OER Texts
This compendium of materials is designed to support the study of tax treaties around the world.
Treaty Shopping And The New Multilateral Tax Agreement—Is It Business As Usual In Canada?, Catherine Anne Brown, Joseph Bogle
Treaty Shopping And The New Multilateral Tax Agreement—Is It Business As Usual In Canada?, Catherine Anne Brown, Joseph Bogle
Dalhousie Law Journal
On 1 January 2020 the Organization for Economic Cooperation and Development’s (OECD) Multilateral Convention (MLI) entered into effect for many of Canada’s tax treaties. New provisions introduced by the MLI, specifically the principal purpose test (PPT) and a new preamble, raised concerns that the bar to deny treaty benefits would be substantially lower than the bar previously set by Canada’s General Anti- Avoidance Rule (GAAR). This paper considers how the MLI will impact access to treaty benefits in Canada by applying the new MLI measures to treaty shopping cases previously challenged under the GAAR. The paper concludes that application of …