Canada has tax treaties with over 90 countries – one of the largest networks in the world.
The March 21, 2013 federal budget announced that the government would consult on possible measures that would protect the integrity of Canada’s tax treaties while preserving a business tax environment that is conducive to foreign investment. To fulfill this mandate, on August 12, 2013, Finance released its consultation paper targeting treaty shopping.
Finance will accept comments on this consultation paper up to December 13, 2013.
The consultation paper defines ‘treaty shopping’ generally as a situation in which a non-resident:
The consultation paper invites comments on seven issues: