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Canada Top Court Blesses Treaty-Shopping Arrangement: The Alta Energy Decision — Orbitax Expert Corner

The Supreme Court of Canada (SCC) recently rendered its eagerly awaited decision in Canada v Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 (Alta Energy). Six of the nine justices held that the Canadian statutory general anti-avoidance rule (GAAR) did not apply to deny treaty benefits under the Canada-Luxembourg Tax Treaty (Treaty) in an...