28 May 2015 IFA Roundtable Q. 2, 2015-0581551C6 - IFA 2015 Q.2: GAAR and treaty shopping -- summary under Article 10

What is CRA's position on the application of the GAAR to treaty shopping arrangements? CRA stated:

The…comments on treaty shopping… made in the February 2014 Budget as well as in the August 2014 Finance news release [do not] preclude[e] the application of the GAAR to treaty shopping arrangements.

The CRA continues to contemplate the application of the GAAR to transactions undertaken primarily to secure a tax benefit afforded by a tax treaty and, in fact, the GAAR Committee has recently approved the application of the GAAR to certain treaty shopping arrangements.

Topics and taglines
Topic
Treaties - Income Tax Conventions - Art. 10
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
313560
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
347041
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