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The Tax Specialist Group is a national affiliation of firms who specialize in providing tax consulting services to other professionals, the CRA can be expected to followup and review the matter, local law in some cases may provide a lower rate of tax irrespective of the treaty.

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For some of these tax treaties the Mutual Agreement Procedure of the MLI 'MLI MAP-tie-breaker' will now be applicable when two states claim the tax residence.

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