IDEAS home Printed from https://ideas.repec.org/a/ctf/journl/v61y2013i3p671-676.html
   My bibliography  Save this article

A Few Thoughts on Treaty Shopping

Author

Listed:
  • Robert Couzin

    (Couzin Taylor LLP, Toronto)

Abstract

The author provides some brief and immediate reactions to the Department of Finance's consultation paper on treaty shopping. These concern certain tax policy issues: the quantification of revenue loss, which implies some normative assumptions; the relevance of the residence of the owner to claims of treaty benefits by a corporation; the role of corporate "substance"; and the distinction between back-to-back conduit arrangements and other possible forms of treaty abuse. The author concludes that policy makers should pay closer attention to the basic principles relating to issues such as these before they focus on the mechanics of a solution.

Suggested Citation

  • Robert Couzin, 2013. "A Few Thoughts on Treaty Shopping," Canadian Tax Journal, Canadian Tax Foundation, vol. 61(3), pages 671-676.
    • Handle: RePEc:ctf:journl:v:61:y:2013:i:3:p:671-676
    as

    Download full text from publisher

    File URL: https://www.ctf.ca/EN/Publications/CTJ_Contents/2013CTJ3.aspx
    Download Restriction: no
    ---><---

    More about this item

    Keywords

    Treaty shopping; policy; tax law;
    All these keywords.

    Statistics

    Access and download statistics

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:ctf:journl:v:61:y:2013:i:3:p:671-676. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    We have no bibliographic references for this item. You can help adding them by using this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Jim Lyons (email available below). General contact details of provider: https://www.ctf.ca/EN .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.