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

IT's been a while since we discussed the famous broken pillars of the OECD. Recent developments however do not bode well for some 148 countries and jurisdictions that signed up or were coerced/cajoled to sign up for the OECD's solution to the problem of profit shifting by multinationals operating in their countries. More than