Document Type

Book Chapter

Publication Date

2024

Source Publication

Li, Jinyan, and Paul Lamarre. International Taxation in Canada. Fifth edition., LexisNexis, 2024.

Keywords

tax treaties; treaty shopping, GAAR; principal purpose test

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.

Download

Request a copy that is accessible using assistive technology (link opens in a new window)

Share

COinS