In the consultation paper, the advisory panel set out the following possible approaches to treaty shopping (paragraph 3.23):

As noted above, certain treaty benefits are afforded to "beneficial owners" who are resident in a treaty country. The CRA has challenged some structures on the basis that the person resident in the treaty country who is

ON the 10th of December, IBFD Tax News Service reported: Nepal Terminates Tax Treaty with Mauritius.

The tax treaty between Nepal and Mauritius was signed at Kathmandu on 3 rd August. 1999. There is nothing very special about this tax treaty that follows the more or less standard template of that time. As