In the consultation paper, the advisory panel set out the following possible approaches to treaty shopping (paragraph 3.23):

As noted above, certain treaty benefits are afforded to "beneficial owners" who are resident in a treaty country. The CRA has challenged some structures on the basis that the person resident in the treaty country who is

IN an earlier episode of this column, we had the occasion to examine tax planning relating to corporate residence and how the Supreme Court's decision in the Tiger Global case -2026-TII-01-SC-INTL put paid to the efforts of paper entities created for the purpose of claiming tax residency in Mauritius to benefit