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Finance committee Yes, this is the first time we are signing an agreement with these three countries.
October 4th, 2010Committee meeting
Alain Castonguay
Finance committee Yes, each of the three countries also has to ratify the agreement in accordance with its legislation. The latest reports indicate that Greece has completed the process and is ready to ratify the treaty. As for Colombia, I am told that the Senate approved the treaty at the end of
October 4th, 2010Committee meeting
Alain Castonguay
Finance committee That is correct. Those two countries must ratify the treaty in order for it to take effect.
October 4th, 2010Committee meeting
Alain Castonguay
Finance committee This is the first time we have had an agreement with Greece, yes. It is a bit of an anomaly because Greece is a part of the OECD. Let's just say the negotiations took a while.
October 4th, 2010Committee meeting
Alain Castonguay
October 4th, 2010Committee meeting
Alain Castonguay
Finance committee Treaties are in force until they are either terminated or amended. We have a network of 87 treaties. Some of them are quite old and they require periodic revision, but these treaties are in force until they are terminated.
October 4th, 2010Committee meeting
Alain Castonguay
Finance committee We negotiate treaties in terms of broader government policies. We ask the department of foreign affairs to advise us of its opinion on these issues. In the case of Colombia, the position of the department of foreign affairs was that a tax treaty was desirable given the trade volu
October 4th, 2010Committee meeting
Alain Castonguay
Finance committee One of the main goals of a tax treaty is to prevent tax evasion. The treaty sets out information-sharing mechanisms under which the Canada Revenue Agency can approach tax authorities in each of the three countries and request information on any taxpayer suspected of failing to me
October 4th, 2010Committee meeting
Alain Castonguay
Finance committee That's right.
October 4th, 2010Committee meeting
Alain Castonguay
Finance committee These bills generally follow the OECD model and our own policy, which is patterned after the OECD model. There are a few things that are different. One of them, for example, is that the taxation of non-resident business in treaties requires a permanent establishment--that is, a s
October 4th, 2010Committee meeting
Alain Castonguay
Finance committee That's right. Our treaty policy is to insist on a rate of 5% for dividends when they are dividends from direct investment, usually defined in treaties as investment above either 10% or 15% equity position, and 15% for other dividends. In the case of Turkey, this is give-and-tak
October 4th, 2010Committee meeting
Alain Castonguay
Finance committee That's right. The rate is bilateral, obviously.
October 4th, 2010Committee meeting
Alain Castonguay
Finance committee As I said earlier, there are no tax treaties that are alike. But essentially they follow our policy. Obviously, withholding stands out in the case of Turkey. I've already talked about the provision of services. One other thing--and it is not major--is that in the case of the se
October 4th, 2010Committee meeting
Alain Castonguay