Tax Treaties

48 Pages Posted: 1 Oct 2024

See all articles by Jinyan Li

Jinyan Li

York University - Osgoode Hall Law School

Paul Lamarre

Davies Ward Phillips and Vineberg LLP

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

Suggested Citation

Li, Jinyan and Lamarre, Paul, Tax Treaties (September 30, 2024). Li, Jinyan, and Paul Lamarre. International Taxation in Canada. Fifth edition., LexisNexis, 2024., Osgoode Legal Studies Research Paper No. 4971944, Available at SSRN: https://ssrn.com/abstract=4971944 or http://dx.doi.org/10.2139/ssrn.4971944

Jinyan Li (Contact Author)

York University - Osgoode Hall Law School ( email )

4700 Keele Street
Toronto, Ontario M3J 1P3
Canada
416-736-5025 (Phone)

Paul Lamarre

Davies Ward Phillips and Vineberg LLP ( email )

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