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

PROVISIONS relating to General Anti-Avoidance Rules though first introduced in the Indian legislation way back in 2012, were actually effectuated only in 2017. In jurisdictions that have put in place statutory GAAR, it has been observed that litigations start surfacing about a decade or so after the introduction of the legislation. In India even