Treaty-shopping is not Inherently Abusive Tax Avoidance in Canada v Alta Energy Luxembourg S.A.R.L.
In Canada v Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 [Alta Energy], the Supreme Court of Canada (“SCC”) unanimously held that taxpayers are entitled to arrange their affairs under international tax treaties to minimize their liability. These arrangements – also referred to as ‘treaty-shopping’ – will not necessarily be considered abusive unless the absence of […]