Treaty-shopping prevention restricts treaty benefits to block non taxation or reduced taxation through evasion or avoidance. The amendment inserts a proviso in section 90(1)(b) conditioning treaty benefits on arrangements not creating opportunities for non taxation or reduced ... Summary
Treaty-shopping prevention restricts treaty benefits to block non taxation or reduced taxation through evasion or avoidance.
The amendment inserts a proviso in section 90(1)(b) conditioning treaty benefits on arrangements not creating opportunities for non taxation or reduced taxation through tax evasion or avoidance, including treaty shopping that seeks indirect relief for residents of other jurisdictions; effective from the first day of April, 2021.
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