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[Music] the oecd G20 beeps project has developed plans to stop treaty shopping which occurs when companies seek to take advantage of tax treaties between two Contracting States using a shell company based in a third jurisdiction a classic example would see company a resident in say the Cayman Islands licensing its intellectual property to company C based in for instance South Africa via a letterbox company based in a European country with a treaty Network allowing for treaty shopping in this example theres no tax treaty in place between the Cayman Islands and South Africa but the European country does have a tax convention with South Africa under which no withholding tax is applied on royalties since the European countrys domestic law does not call for withholding tax on outbound payments royalties for the group are not taxable in either companies a b or c whats the solution the bes project will require countries to adopt at a minimum rules designed to ensure that only true residen
