Tag archives: OECD

Treaty won, battle lost? Reviewing developments in international tax law

By Elisabeth Trotter (Calgary) on November 6, 2018 Posted in Tax

No one would ever suggest international tax law is simple, but with Canada’s impending ratification of the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “MLI“), a new layer of complexity has been added when determining whether a taxpayer is eligible to receive a particular treaty … Continue reading

Beware the zombie invasion (stock exchange edition)

By Troy Ungerman (Toronto) on October 9, 2018 Posted in Cannabis, Corporate finance, Infrastructure, mining and commodities

On September 18, Deloitte released a new report which outlines a roadmap for the competitive business climate in Canada. Included in the report is a warning that “Canada may have a zombie problem.” Luckily, Deloitte isn’t raising concern about hordes of flesh-eating undead, but rather the relatively large number of “zombie companies” that exist on … Continue reading

Canada’s first post-BEPS tax treaty: implementing the new treaty shopping proposals

By Troy Ungerman (Toronto) on November 15, 2016 Posted in M&A, Tax

Last November, we told you about the new treaty shopping rules proposed by the Organisation for Economic Co-operation and Development (OECD) as part of the final report on Action 6 of the Action Plan on Base Erosion and Profit Shifting (BEPS Action Plan). The main proposal in Action 6 was the amendment of the OECD … Continue reading

OECD report proposes new treaty shopping rules

By Troy Ungerman (Toronto) on November 10, 2015 Posted in Corporate finance, Tax

In February we wrote about a discussion draft of Action 6 of the Action Plan on Base Erosion (BEPS Action Plan) developed by the Organisation for Economic Co-Operation and Development (OECD) at the request of the G20. In October, the OECD published its final report on Action 6 of the BEPS Action Plan. Action 6 … Continue reading