Treaty shopping and Tax Residency Certificate challenges failed as no substantial question of law arose.

Treaty shopping was not made out on the facts, and the Tax Residency Certificate could not ordinarily be questioned or disregarded except on limited grounds. The court found no factual foundation to depart from that binding principle, so no substantial question of law arose and the appeals were dismissed.

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Issues: Whether any substantial question of law arose on the challenge relating to treaty shopping and the Tax Residency Certificate.

Analysis: The appeals were examined in the light of the binding view that treaty shopping would not arise on the facts, and that a Tax Residency Certificate cannot ordinarily be questioned or gone behind except on limited grounds. No factual foundation was shown to justify departure from that principle.

Conclusion: No substantial question of law arose. The appeals were dismissed.

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