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

ON January 15, 2026, the Supreme Court of India - 2026-TII-01-SC-INTL seems to have finally laid the ghost of Azadi, Vodafone and CBDT circular 789 to rest. It was a very comforting world for India's tax planning community - form a company in Mauritius, get a GBL-1