A November 2021 judgment from Trinidad and Tobago's Court of Appeal was recently published regarding the domestic anti-avoidance rule and treaty shopping involving Barbados, the Cayman Islands, and Canada.
The case concerned withholding tax on dividend payments made by Methanex Trinidad Unlimited (Methanex Trinidad) to Methanex Trinidad Holdings Limited in Barbados (Methanex Barbados). Methanex Barbados then paid equivalent dividends to Methanex International Holdings Limited in the Cayman …