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

NON-RESIDENT taxation seems to have finally entered mainstream policy making in India with the Finance Minister announcing a slew of substantial changes in this area in the Budget presented on the 1st of February 2026.

In the area of non-resident taxation, the provision that has got maximum attention is the proposal for