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Global tax structures require businesses to plan any investment with efficiency to optimise the benefits which can be availed from the use of Double Tax treaties. The simple days of Treaty Shopping are now in the distant past with the active involvement of the OECD to drive the global tax initiative to ensuring that all companies pay their fair share of taxes. Substance based initiatives are now guiding principal to ensuring that companies operate on a level playing field globally.

With the move to achieving a Global Minimum Tax of at least 15% in each jurisdiction, there is even more pressure for companies globally to prepare for this eventuality.