Canada signals tougher stance on treaty shopping

In a recent Tax Notes International article, Michael Kandev and Taj Kudhail review the Husky Energy decision of Canada's Federal Court of Appeal and explain its implications for addressing alleged treaty shopping. The article discusses how the Court upheld the denial of reduced dividend withholding tax benefits under the Canada-Luxembourg treaty in an alleged treaty shopping structure involving Barbados and Luxembourg entities, and summarizes the court's ruling and comments.

The full article, originally published by Tax Analysts, can be found at Tax Notes International or by downloading the PDF from our website.