International Tax Planning: Canada v. Alta Energy Luxembourg SARL—An Analysis Based on the Vienna Convention on the Law of Treaties

Abstract

The author analyzes the Supreme Court of Canada's judgment in Canada v. Alta Energy Luxembourg SARL in light of the rules of the Vienna Convention on the Law of Treaties (VCLT), including general principles of law such as good faith and legal certainty pursuant to the principle of systemic integration set out in article 31(3)(c) of the VCLT. The author concludes that the findings of the majority are correct as a matter of public international law.