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

MOVING away from the topsy turvy Trumpian world, let us for the moment, go down under- to Australia. In August 2025, the High Court of Australia (the highest Court of appeals in Australia), gave its first verdict involving the Australian Diverted Profits Act (DPT). The same decision also dealt with the vexed issue