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

MR. Donald Trump, the 45th and 47th US President had announced his "reciprocal tariffs" on several countries, big or small, friend or foe alike on the so-called Liberation Day- 2nd April, 2025. According to the calculation then made, India was to be graced with a 25% tariff. There were other countries in the