Canada - Treaty shopping consultation submission 

December 24: In response to the Canadian government’s consultation paper on treaty shopping, the KPMG member firm in Canada made a submission of items that the Department of Finance might consider in determining whether a separate treaty shopping measure is required or appropriate at this time.

Overall, KPMG submitted that:


  • It may not be necessary to introduce new measures to combat treaty shopping at this time.
  • Unilateral measures could even be detrimental for Canadian multinational businesses and Canada’s relationships with its trading partners.
  • Canada currently has adequate resources and tools to police treaty shopping in its tax treaties and domestic law, including the general anti-avoidance rule, and in international jurisprudence.

KPMG suggested that a “wait-and-see” approach may be the most prudent course of action as it may allow Canada to observe other countries’ experiences with anti-treaty shopping provisions over the longer term and formulate a more measured response.


Read a December 2013 report [PDF 205 KB] prepared by the KPMG member firm in Canada: KPMG’s submission to the Consultation on Treaty Shopping




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