Bilateral tax treaties have served to prevent harmful double taxation and remove obstacles to cross-border trade in goods and services, and movements of capital, technology and persons.
- This extensive network of tax treaties has, however, also given rise to treaty abuse and so-called “treaty-shopping” arrangements.
- Treaty shopping typically involves the attempt by a person to indirectly access the benefits of a tax treaty between two jurisdictions without being a resident of one of those jurisdictions.