3 [30 MARKS] (a) The basic concept in tax planning encompasses Tax avoidance, Tax evasion and Tax mitigation and they are not distinct and separate from each other. You are required to discuss this statement. [10 Marks] (b) Many multinationals divert Foreign Direct Investment (FDI) through conduit countries that have a favorable tax treaty network, to avoid host country withholding taxes. This is referred to as tax treaty shopping. (i) Explain using an illustrative example what you understand by treaty shopping. [10 Marks] (ii) Most Double Taxation Agreements (DTAs) contain a limitation on benefits clause. This entails a number of alternative tests to ensure that DTA benefits are extended to only those residents of a contracting state