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ARTICLE · 21 DECEMBER 2016

How Is BEPS Reflected In Canada's Newest Treaties?

Davies Ward Phillips & Vineberg LLP
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In this article, the authors examine the extent to which Canada's new treaties with Taiwan and Israel reflect its involvement and concern.

CanadaTax
Nathan Boidman
Nathan Boidman
Michael Kandev
Michael Kandev
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In the year since the final reports of the OECD's base erosion and profit-shifting project were released and approved by the G-20, Canada has signed new income tax treaties with Taiwan1 and Israel.2 That makes it timely to consider the extent to which Canada's post-BEPS treaties reflect the BEPS recommendations, which Canada helped to develop.

This article deals with that question in two parts: first, regarding the treaty shopping rules proposed in action 6, and second with the other treaty rules proposed in action 7; in both cases, thought will be given to how the action 15 multilateral instrument (not yet released) could affect Canada's two post-BEPS treaties and those that came before.

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