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Abuse of rights and treaty shopping: a Canadian prelude to the application of the PPT clause?

6 December 2018
The Tax Court of Canada recently adopted a restrictive position concerning the possibility for a general anti-abuse rule provided under domestic law to challenge the application of a bilateral tax treaty whose benefits have essentially been claimed for tax purposes. The reasoning of the Canadian judge is particularly interesting in today’s context, since international tax treaties will progressively include the PPT clause, a general anti-abuse rule set-up in order to fight against treaty shopping.

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