Tax Treaties
48 Pages Posted: 1 Oct 2024
Date Written: September 30, 2024
Abstract
Canada has close to 100 bilateral tax treaties and an active body of case law on treaty interpretation, including the recent Supreme Court of Canada decision in Alta Energy S.A.R.L. v. Canada (2021 SCC 49) on treaty shopping. This chapter in a forthcoming book examines Canada's treaty network, interpretation issues, the impact of the MLI and the relationship between the domestic GAAR and the principal purpose test in the MLI.
Note: Excerpt below from International Taxation in Canada, 5th Edition (ISBN: 9780433532255) by Jinyan Li and Paul Lamarre. Reproduced with permission. © 2024 LexisNexis Canada Inc. All rights reserved.
Keywords: tax treaties, treaty shopping, GAAR, principal purpose test
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