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ARTICLE · 09 JULY 2015

Treaty Shopping Update

McCarthy Tétrault
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Treaty shopping has received a great deal of attention in Canada in recent years.

CanadaTax
Ryan Rabinovitch
Ryan Rabinovitch
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Introduction

Treaty shopping has received a great deal of attention in Canada in recent years. Significant interest was initially generated by the federal government’s announcement in 2013 that it intended to adopt specific measures designed to curb the practice. Around the same time, the Organisation for Economic Co-operation and Development (OECD) released its Action Plan on Base Erosion and Profit Shifting (BEPS), which indicated that working groups would be tasked with formulating recommendations regarding certain issues or “actions,” including the prevention of treaty abuse (Action 6). Both the government’s and the OECD’s initiatives have undergone important developments over the past two and a half years. This article provides an overview of those developments and the current status of each initiative.

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