On 1 January 2020 the Organization for Economic Cooperation and Development’s (OECD) Multilateral Convention (MLI) entered into effect for many of Canada’s tax treaties. New provisions introduced by the MLI, specifically the principal purpose test (PPT) and a new preamble, raised concerns that the bar to deny treaty benefits would be substantially lower than the bar previously set by Canada’s General Anti- Avoidance Rule (GAAR). This paper considers how the MLI will impact access to treaty benefits in Canada by applying the new MLI measures to treaty shopping cases previously challenged under the GAAR. The paper concludes that application of the PPT by Canadian courts will result in similar outcomes in these cases. In short, the MLI will ar...
The heated political debate on aggressive tax practices of multinational entities starts to produce ...
La double imposition des revenus et du capital constitue un obstacle certain au commerce internation...
This paper aims to inform international tax policy development in light of three of the most promine...
On 1 January 2020 the Organization for Economic Cooperation and Development’s (OECD) Multilateral Co...
On November 9, 1995, Canada and the United States ratified the Third Protocol to the Canada-US. Inc...
The Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shif...
Over the last 40 years, the world has experienced exponential growth in international trade and inve...
Relative to at least some high-income countries, Canada has been willing to negotiate tax treaties t...
The Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shif...
The article looks at the public international law aspects of the BEPS Convention adopted in 2016 and...
The general claim of this thesis is that the Canadian tax system should adopt a functional approach ...
This article will proceed as follows. Section 2 summarizes the main provisions of the MLI. Section 3...
The book explores the problem of abuse prevention in tax treaty law from the 1977 OECD Model Tax Con...
The Multilateral Convention (Multilateral Instrument to Modify Bilateral Tax Treaties – MLI) is an i...
This article examines the Multilateral Convention to Implement Tax Treaty Related Measures to Preven...
The heated political debate on aggressive tax practices of multinational entities starts to produce ...
La double imposition des revenus et du capital constitue un obstacle certain au commerce internation...
This paper aims to inform international tax policy development in light of three of the most promine...
On 1 January 2020 the Organization for Economic Cooperation and Development’s (OECD) Multilateral Co...
On November 9, 1995, Canada and the United States ratified the Third Protocol to the Canada-US. Inc...
The Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shif...
Over the last 40 years, the world has experienced exponential growth in international trade and inve...
Relative to at least some high-income countries, Canada has been willing to negotiate tax treaties t...
The Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shif...
The article looks at the public international law aspects of the BEPS Convention adopted in 2016 and...
The general claim of this thesis is that the Canadian tax system should adopt a functional approach ...
This article will proceed as follows. Section 2 summarizes the main provisions of the MLI. Section 3...
The book explores the problem of abuse prevention in tax treaty law from the 1977 OECD Model Tax Con...
The Multilateral Convention (Multilateral Instrument to Modify Bilateral Tax Treaties – MLI) is an i...
This article examines the Multilateral Convention to Implement Tax Treaty Related Measures to Preven...
The heated political debate on aggressive tax practices of multinational entities starts to produce ...
La double imposition des revenus et du capital constitue un obstacle certain au commerce internation...
This paper aims to inform international tax policy development in light of three of the most promine...