Treaty abuse prevention: tax treaties must prevent treaty shopping and non taxation, blocking avoidance that secures indirect treaty relief.

Amendment to section 90(1)(b) requires that agreements for avoidance of double taxation be entered into without creating opportunities for non taxation or reduced taxation through tax evasion or avoidance, including treaty shopping arrangements that secure treaty reliefs for the indirect benefit of residents of other countries or territories; the amendment takes effect from 1 April 2021 and applies to the 2021 2022 assessment year and thereafter.

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