Bill S-17 (Historical)

Tax Conventions Implementation Act, 2013

An Act to implement conventions, protocols, agreements and a supplementary convention, concluded between Canada and Namibia, Serbia, Poland, Hong Kong, Luxembourg and Switzerland, for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes

This enactment implements four recent tax treaties that Canada has concluded with Namibia, Serbia, Poland and Hong Kong. This enactment also implements amendments to provisions for the exchange of tax information found in the tax treaties that Canada has concluded with Luxembourg and Switzerland.
The tax treaties with Namibia, Serbia, Poland and Hong Kong are generally patterned on the Model Tax Convention on Income and on Capital developed by the Organisation for Economic Co-operation and Development (OECD). The amendments to the treaties with Luxembourg and Switzerland ensure that their provisions for the exchange of tax information reflect the current OECD standard on this matter.
Tax treaties have two main objectives: the avoidance of double taxation and the prevention of fiscal evasion. Since a tax treaty provides relief from taxation rules in the Income Tax Act, it becomes effective only after being given precedence over domestic legislation by an Act of Parliament such as this one. Finally, for each instrument implemented by this Act to become effective, it must be ratified after the enactment of this Act.

Tax Conventions Implementation Act, 2013

[Philip Toone, NDP, Gaspésie—Îles-de-la-Madeleine, QC]

Mr. Speaker, I would like to thank the member for Victoria.

I know that he works very hard in his riding, and I am sure that his constituents greatly appreciate the fine job he does representing them in the House of Commons. His comments on fiscal issues are second to none.

Today being Tax Freedom Day, the member has made it very clear that when it comes to overseas tax evaders everyday is Tax Freedom Day. The government has a lot to be reproached about for making it possible for Canadians to celebrate Tax Freedom Day today, but it is not talking about everyone else who is evading paying their taxes. This day could actually come much more quickly than what the government leads us to believe.

We need to work a lot harder at this. The member's speech made it clear that there were a lot of things we could do that could lead to much better tax fairness in the country.

Just today, Canadians for Tax Fairness indicated that Statistics Canada surveys have indicated that overseas Canadians are putting away in the 12 biggest tax havens in the world over $170 billion worth of revenue that the government could be taxing. I wonder if the member could speak more to the fact that perhaps the government is unaware that all of this money is available.

What makes the Conservative government so slow at reacting to this when we know this money should be taxed in order to pay for the services Canadians deserve?

[Murray Rankin, NDP, Victoria, BC]

Mr. Speaker, the amount of money that the same organization, Canadians for Tax Fairness, has indicated every year is lost bears repeating. Its study shows it is $7.8 billion. The Tax Justice Network, of which it is a part, has done enormously good work around the globe in trying to come up with a figure. As I said, the Conservative government refuses to even try to measure that tax gap.

I think the reason the government does not see this as a problem is that it does not see it through the lens of investment. If it characterized this as making an investment of a few billion dollars in return, maybe that would get through to it, maybe then it would see that this could be an investment well worth making.

It is an issue of fairness all right because that $7.8 billion would, as my hon. friend said, allow us to reach Tax Freedom Day months earlier, because that $7.8 billion would now be available, even some portion of it, so we would have more money so Canadians would achieve tax fairness a few weeks or months earlier.

There are fairness issues and there are equity issues, but there are simple bottom line issues. If the government saw it as an investment, maybe then it would get it.

[Anne Minh-Thu Quach, NDP, Beauharnois—Salaberry, QC]

Mr. Speaker, I would like to thank the member for Victoria for yet another informative speech. He always provides statistics and specific examples. It is clear that he does his homework before sharing his point of view.

Something he said earlier really struck me. A total of 3,000 full-time positions will be cut at the Canada Revenue Agency. The people being cut will not be able to investigate the money being lost to tax havens. Billions of dollars are lost and are not being reinvested into the fight against climate change, for example. It would mean more money in our economy.

The Conservatives made $29 million in cuts to Parks Canada when we are trying to attract visitors. Our parks create ecotourism jobs, for example, which means jobs for the regions. The Conservatives are slashing family farms. They are cutting everywhere; meanwhile, the money from uncollected taxes could be reinvested in my area's economy, ensuring sustainable, high-quality positions.

Can the member again explain how all these job cuts—and the fact that we are losing money that should be coming back to us from companies—are negatively affecting our economy?

[Murray Rankin, NDP, Victoria, BC]

Mr. Speaker, I appreciate that the hon. member has put these cuts in the personnel of the Canada Revenue Agency in a very interesting context and much broader context. She talked about parks, climate change, family farm regulation and so forth.

The cuts the government has made to public services to Canadians are having real impact. I know the Conservatives like to say that these are back office jobs that have been cut and we should not worry, that it will not affect their fight against tax havens. That is what they say in the context of CRA.

In my community of Victoria, I keep getting seniors telling me that they do not have telefile anymore. There is no front counter service. That has all been cut. It is as if we are supposed to believe, with the millions and millions of dollars that have been cut and, if I use the government's figures, 2,568 more people will be cut after the budget goes through, that this has no consequence in the real world.

What do the Conservatives think we are? Of course there will be consequences and the examples the hon. member has given on climate change and parks are just examples that we could replicate throughout Canada Revenue Agency's experience just as much.

[Kevin Lamoureux, Liberal, Winnipeg North, MB]

Mr. Speaker, it is a pleasure to rise to speak to Bill S-17. Taxation and taxes is always a hot topic. No matter what day of the year it is people always want to talk about taxes. One thing that they like to tie to taxes is the idea that it is an absolute necessity. Government has to generate revenues and part of those revenues is taxes. I will make reference to a multitude of different types of taxes shortly.

I will first start off from the whole aspect of what I made reference to earlier today. There are some bills that I believe are fairly straightforward, standard and receive a considerable amount of support. When we look at Bill S-17, we find there is substantial support of all entities in the House to see the bill ultimately pass. The objections are reasonable in what it wants to accomplish. I do not think we have too many advocates suggesting that we should be creating tax havens. We might hear some differences in whether the government is doing enough. Again, I will provide some further comment on that point shortly.

First and foremost, what I want to start off with is why we have Bill S-17 before us today and the manner in which the government has brought it forward. It concerns me because even though the bill we have before us is relatively non-controversial, the government has made it more controversial. The reason why we might want to speak to it that much more is because of the manner in which the government has chosen to bring in the legislation.

I have been a parliamentarian for a number of years and have had the opportunity to negotiate session wind-ups, albeit at the provincial level, but it is a parliamentary system very similar to the type of procedures that happen in the House of Commons. As we look to our days winding down here, in my beloved home province of Manitoba the legislature is winding down its session. However, it looks as though its session will go on well into July if we believe some of the reports. What is interesting about that with respect to the relevancy of that bill is that it is all about taxes.

In Manitoba, the NDP government of the day is increasing the provincial sales tax from 7% to 8%. There is an issue surrounding the balanced budget legislation. There was supposed to be a referendum, but that was not held. I suspect the reason being is that the government would likely lose the referendum because there is no appetite to see the provincial sales tax increased, especially when the province next door is decreasing its sales tax and that gap continues to grow. The bottom line is there is a bit of a stalemate happening there.

As much as I might not necessarily be a strong advocate for the New Democrats in the province of Manitoba, I do respect the fact that they are going through a process and are not yet putting in limits in the form of closures, from what I understand. This is with respect to a bill that is exceptionally controversial and no doubt will receive hours of debate and go into committee, which is a different system. I believe there are close to 200 Manitobans who have expressed an interest in wanting to talk about taxes in that legislation. Therefore, there is what I classify as due process. There they have controversial legislation where there is no unanimity within the legislative chamber.

Contrast that to Ottawa, where we have a bill, subject matter, taxes, tax evasion and tax havens. We seem to have wide support for the bill and its passage, yet we have a government that has brought in time allocation. This is not the first time it has brought in time allocation. I believe this is already the 40th, 41st or 42nd time that the government has brought in time allocation. I have had the opportunity on numerous occasions, probably 30 times or even more than that, to stand in my place to talk about the serious nature of time allocation. It is serious, when we have a majority government making a decision before the House to define the amount of time to be allocated for debating Bill S-17.

When I listened to the Minister of State for Finance, he indicated that we have had a piece of legislation before the House for 100 days, trying to give people who may be following the debate the impression that for 100 days, we have actually been debating Bill S-17, and that the government is doing us a huge favour by bringing in time allocation.

Nothing could be further from the truth. We might have had a few hours, not even a full day of real debate inside the House of Commons on this issue, yet it is the perception. The government has made the decision that it will limit the amount of opportunities for members of Parliament to address the issue of taxes.

When I had the opportunity to review Bill S-17, I had the opportunity to talk about taxes in general and the whole issue of fair taxation, spending smarter and so forth. I believe that is what the constituents of Winnipeg North would want me to do, to express concerns I might have on the legislation and to talk about taxation policies.

We have 300-plus members of Parliament, and the government has said that it wants a very limited number of MPs allowed to speak to this legislation. I am grateful to my party. It made sure I was afforded the opportunity to express my concerns. On this bill, I suspect that if there was any goodwill coming from the government House leader, maybe even working with the Minister of Finance and approaching opposition parties, negotiating, talking about what kind of legislation it is, how many hours would we like, then respective caucuses could work with their colleagues to get a sense of how long the debate could or should be.

We have all sorts of ways to enable legitimate, full, wholesome debate on bills that are deemed important, where members of Parliament want to stand up and address their concerns. The government, through this whole time allocation addiction it has, is preventing that.

The unfortunate things is that in principle we support Bill S-17 because of its objectives and what it hopes to accomplish. I suspect it may not even have required five hours of debate. I do not know, because we had no sense of interest within our own caucus or whether it was brought to our caucus; I have no idea how many New Democrats would have chosen to speak to it.

Even though in principle I support the bill we are talking about, what upsets me is the fact that the government continues to use time allocation in order to get through its legislative agenda.

I want to emphasize how important it is that we recognize that we have seen a significant change in attitude in the Prime Minister ever since he received his majority Conservative/reform government. It has been a significant shift in attitude. He has been very disrespectful toward individual members when it comes to their participation in debate.

The government has invoked time allocation, another form of closure, on legislation that definitely should have had a lot more debate. As a result of the government's inability to negotiate in good faith, now we find that every time it introduces a bill, either one day later or even sometimes on the same day, a time allocation motion is invoked. We are seeing that again today on Bill S-17. That lack of respect for proper procedure inside the House of Commons is going to hurt the government. Conservative members may not realize that today, but at the end of the day, it will have an impact.

Canadians respect our democratic system. They appreciate the fact that there is a proper process to be followed. The degree of the Conservative government's lack of respect for due process will become better known. It is an issue I plan to raise significantly going forward, because the frequency is the greatest insult to the House.

I will conclude my remarks on the issue of the process by saying very clearly that no government in the history of Canada has used time allocation in the fashion the Conservative government has, and we are only two years in to a majority government. I want to emphasize that particular point.

Let me get to taxation.

When we look at what the bill would ultimately do, we think of achieving bilateral agreements. What we are attempting to do is ratify them through this legislation. We can have as many of these bilateral agreements as ultimately can be developed and passed through the House, but that will not really address the issue to its fullest degree. If we want to deal with the issue of tax avoidance or people hiding money or not paying their fair share, then we have to look at resources and to what degree we are allocating resources to those authorities, such as the Canada Revenue Agency, and its ability to go after those individuals who feel they do not have to pay their fair share of taxes.

Former prime minister Paul Martin allocated $150 million to combat international tax evasion. We took the issue of tax evasion very seriously, so $150 million was put in the Liberal Party's last budget in order to combat tax evasion. If we follow that through, in 2009 we could ultimately argue that $150 million had a fiscal impact of about $2.5 billion. When we think of how effective that $150 million was in terms of being able to return $2.5 billion to the coffers in some fashion or another, that shows very clearly and decisively just how effective it would be to allocate the appropriate resources in order to avoid tax evasion. That is very important.

The other issue is with respect to bilateral information. At the end of the day, bilateral information or establishing some sort of an exchange framework is one way to deal with this. Those who participate in tax evasion are very creative: they come up with different ways to avoid having to pay taxes. Working toward the larger, multilateral information exchange framework is ultimately the next best way, I would argue, to clamp down on those companies that are participating in tax evasion.

I want to very briefly comment on the issue of taxation, in general.

We all know that governments need to have revenue in order to function. What I would like to see, and I believe what most Canadians want to see, is that the money collected is in fact being spent smart. As a taxpayer, I want, number one, to pay my fair share. I do not want to have to pay more, but I am prepared to pay my fair share. I think a vast majority of Canadians have that attitude. The other concern is that they want the sense that those tax dollars are being spent wisely.

On both of those fronts, there is a wide belief that this is not taking place today. It does not matter what level of governance, there is this suspicion that the government is just not doing enough. I think what we need is the Prime Minister and his government to take the issue of tax evasion more seriously and look at how we can have multilateral agreements to ensure that those who try to avoid paying taxes are held accountable. The government, the Canada Revenue Agency, must be empowered to do what is necessary to ensure that people pay their fair share. I believe that is quite reasonable.

When I look at Bill S-17, it is a step forward. However, I do not believe that the government is doing enough. All we need to do is look at the last Paul Martin budget where there was a huge investment of tax dollars to deal with the issue of tax evasion. The return for that $150-million investment was overwhelmingly positive.

If the government had its priorities right, I think that there is so much more out there that we could benefit from. A more aggressive government would ensure that all Canadians paid their fair share.

I will save my comments in terms of spending that money in a better fashion for another debate on another bill. For now, suffice it to say, there needs to be a lot more improvement.

I will conclude my remarks by saying when we talk about taxes, it is important that we recognize that taxes come in many different forms, whether it is hiking up tariffs, the PST, income tax and many others. I look forward to this bill passing. If there are any questions, I am more than happy to answer.

[Philip Toone, NDP, Gaspésie—Îles-de-la-Madeleine, QC]

Mr. Speaker, I thank my hon. colleague for his interesting remarks. However, they were sometimes difficult to follow. It is hard to know whether the information was 100% reliable.

For instance, he said:

Those who participate in tax evasion are very creative.

I would like to point out that Paul Martin himself was perhaps a little too creative when it came to tax evasion. Representatives of his family business, Canada Steamship Lines, were repeatedly criticized for failing to pay their fair share when they created subsidiaries in Barbados, for example. Barbados is a known tax haven.

Frankly, it is pretty hard for us to understand how the Liberal Party can tell us that, on the one hand, it spent up to $150 million to fight tax evasion, while on the other hand, the prime minister of the day owned a business that seemed to be evading taxes. I am having a very hard time understanding my Liberal colleague's logic.

If Canada Steamship Lines, which has subsidiaries in Barbados, did not pay its fair share in either Canada or Barbados, how is it that the Government of Canada spent $161 million on contracts with Canada Steamship Lines and its subsidiaries until 2004, the last year for which I have statistics, yet Canada Steamship Lines did not pay its fair share of taxes?

I am having a very hard time understanding my Liberal colleague's point. I would like him to explain Paul Martin's tax evasion.

[Kevin Lamoureux, Liberal, Winnipeg North, MB]

Mr. Speaker, the important word the member used was “seemed”. He said it seemed as if there was tax evasion. If the member genuinely believed what he is trying to give the impression of to those who might be watching, then he should feel comfortable enough to go outside of the House of Commons chamber and say that the former prime minister did some sort of illegal activity and make the accusation he just made here outside the House. I suspect his comments would be greatly watered down.

If we want to talk about individuals, we have to be very careful. If I were to bring up individuals, much as we have seen the Conservative caucus do during S. O. 31s, where they constantly cite not one but two NDP, and I underline “NDP”, members of Parliament who are not paying their taxes. The member needs to be very careful. I would argue that there is an equally strong case to be made, if not a stronger case to be made, with regard to his two colleagues, members of Parliament who sit with him today, than there is with former prime minister Paul Martin. If he believes that Paul Martin did something illegal, then I would challenge him to have the courage to say outside the House that there was illegal activity and let Canada Revenue Agency know about it. However, I suspect he would not do that. I suspect that because he used the word “seemed”.

Let there be no doubt that there are many Canadians across the country who, when they process their tax returns, look at ways to minimize the amount of tax they have to pay, and there is nothing wrong with doing that. The problem is when individuals choose not to pay their taxes, as are the allegations with two of his colleagues, which is a problem, or when people conduct themselves in an illegal way to avoid paying taxes.

I do not think the Liberal Party has to make apology any more than the New Democratic Party, especially if we apply the relevance of time. As of today, there are two members of his own caucus whose behaviour is being questioned on the issue of paying their fair share of taxes.

[Jasbir Sandhu, NDP, Surrey North, BC]

Mr. Speaker, I heard the question from my hon. colleague, and I think he was talking about closing the loopholes that currently exist in our system. The newspaper this morning said that Canadians for Tax Fairness cited recent statistics from Statistics Canada that show that in the top 12 tax havens around the world, Canadians have stocked away $170 billion. If we taxed those $170 billion, we could have $7.8 billion in additional revenue. Where is that additional revenue going now? It is going on the backs of Canadians.

I googled “tax evasion” just now, and the top four or five news articles say that France is expanding its inquiry of tax evasion, India is also going after tax evaders, the U.S. is cracking down on virtual currency tax fraud and the headline in the Ottawa Citizen says, “Canada slammed for lagging behind in fighting tax evasion...”. This is from just punching it into Google. This is just today's news.

I know the G8 summit is taking place. It would appear that Canada has been dragging its feet and we can do more to collect that $7.8 billion. I would like the member to comment on that, please.

[Kevin Lamoureux, Liberal, Winnipeg North, MB]

Absolutely, Mr. Speaker. I applaud the member for the question. At the end of the day, we lose billions of dollars in annual revenues that should be coming into our coffers. Can anyone imagine what we could do with those billions of dollars? It could go to deficit reduction, reducing other forms of taxes for the middle class and others, or not having to increase other forms of revenue. If only we had a government that was prepared to do more.

Canada is lagging behind, and that is the reason I used the example of the $150 million that was put into fighting tax evasion back in 2005 under the last Liberal administration. That $150 million is ultimately responsible for generating close to $2 billion. That is a whole lot of money that I would argue assisted in preventing us from having to increase other taxes.

Again, I want to emphasize that Canadians as a whole believe that taxation is something in which people have to participate. People have to pay taxes, but we ask that taxes are fair and that we do not allow individuals to get away with things such as tax evasion. This upsets people, and justifiably so. People who put in 40-hour work weeks making $20 or $25 an hour, or whatever it might be, are paying hard taxes. They want to ensure that the guy who is making $3 million a year or $500,000 a year is also paying his taxes. They have a right to feel comfortable in knowing their government truly cares, to the degree in which it is going to fight to ensure that everyone is paying their fair share.

We need to invest more time, energy and resources, and work toward international multilateral agreements on information sharing.

[Wladyslaw Lizon, Conservative, Mississauga East—Cooksville, ON]

Mr. Speaker, I appreciate the opportunity to speak today to the second reading of Bill S-17, the tax conventions implementation act, 2013.

Over the years, our government has worked hard at signing many tax treaties to help improve our system of international taxation. Bill S-17 would add to Canada's ongoing measures to update and modernize its network of income tax treaties with other countries, which is one of the most extensive in the entire world. Canada has tax treaties in place with a whopping 90 countries, including most of our major trading partners, and is working on agreements with other jurisdictions. Bilateral income tax treaties like the one before us today help us to prevent double taxation, thus creating tax fairness for all Canadians, and ensure everyone pays their fair share, something we know we must do.

Tax treaties also eliminate tax barriers to trade and investment. As we noted in the economic action plan 2013, deeper trade and investment relationships in more overseas markets help support jobs and growth in Canada. In this respect, Bill S-17 would provide benefits to both taxpayers and governments by setting out clear rules that would govern tax matters relating to cross-border trade and investments. The treaties covered in Bill S-17 would promote certainty, stability and a better tax climate for taxpayers and businesses in Canada and these treaty countries. While these treaties would help to secure Canada's position in the increasingly competitive world of international trade and investment, they would also help combat tax evasion.

While Bill S-17 is a relatively standard, routine and innocuous piece of legislation, these new and updated treaties would strengthen Canada's already-strong network of tax treaties. Bill S-17 proposes to implement tax conventions, either new or updated, with Canada and Namibia, Serbia, Poland, Hong Kong, Luxembourg and Switzerland. With these six new and updated treaties adding to the 90 tax treaties already in existence, we could be proud that Canada boasts one of the largest networks of bilateral tax treaties, ensuring a fair and competitive international tax system.

I mentioned previously why the legislation before us today is a standard fare, but it is nonetheless very important in achieving the above goals. Bill S-17 would help to stop tax cheats and help to combat tax evasion. It would create tax fairness and prevent double taxation. Finally, it would help improve international trade and investment.

Cyndee Todgham Cherniak of LexSage Professional Corporation said this recently to the Senate banking committee:

Tax treaties facilitate trade. Tax treaties are symbols of cooperation, trust and friendship between nations. Tax treaties prevent double taxation.... They improve stability, transparency, fairness, procedural fairness and tax certainty relating to international trade and transactions. Tax treaties are good for Canadian businesses with activities abroad through branches, subsidiaries and other business enterprises. Tax treaties are good for individuals, employers, directors of corporations, students, shareholders, et cetera.

We can all agree on the importance of working with other countries to provide tax fairness for Canadians, and the bill before us today would do just that.

Tax treaties like those in Bill S-17 complement our Conservative government's overall commitment to a more competitive tax system, one that improves the standard of living of all Canadians. Tax treaties like those in Bill S-17 directly support and encourage cross-border trade in goods and services, which in turn helps Canada's domestic economic performance.

Moreover, Canada's wealth as a proud trading nation depends on a strong global marketplace where information, investment and technology flow with ease.

In fact, during the Senate committee's examination, Nick Pantaleo, a well-respected tax expert with PricewaterhouseCoopers LLP, remarked that:

...a key objective of the Canadian government is to pursue new and deeper international trade and investment relationships. This is not surprising given that more than 60 per cent of the Canadian economy and one in five jobs in Canada are generated by trade. In my view, tax treaties contribute towards the success of such global trading arrangements.

Accordingly, the tax treaties contained in Bill S-17 are a critical tool in strengthening Canada's trade and investment relationships, creating jobs for Canadians here at home.

How does Bill S-17 do that? I would like to take a moment and discuss one particular issue dealt with in this legislation and tax convention implementation through the years, preventing something called double taxation.

Double taxation in the international sense arises as a result of the imposition of taxes in two or more countries on the same taxable income for the same period of time. The treaties in Bill S-17, through bilateral rules, would help avoid double taxation and ensure that taxpayers pay tax on the same income only once.

The Canadian income tax system generally taxes residents on their worldwide income. However, in recognition of the fact that a foreign country may also have a right to tax income earned in that country by a Canadian resident, Canada will provide a credit for foreign income taxes paid, and vice versa. Indeed, if this rule did not exist, there would be unfair consequences for taxpayers, who would be punished for trying to grow or expand their Canadian businesses internationally.

Simply put, nobody should have their income taxed twice—at least, this is what we think on this side of the House. The exception may be the high-tax NDP. Unfortunately, without a tax treaty like those contained in Bill S-17, that is exactly what would happen, and I am happy this legislation will address that problem.

In the time I have left today, I would like to single out how Bill S-17 would be beneficial to Canada's relationship with its dear friend, Poland.

Canada and Poland enjoy a close relationship, including growth in trade and investments as well as increasing military co-operation and academic relations programs. Canada is home to a vibrant community of nearly one million Polish-Canadians, and since 2008, Poles can travel to Canada visa-free with their e-passports, further expanding people-to-people ties among our citizens.

In February 1998, Canada was the first North Atlantic Treaty Organization country to ratify Polish accession to the organization. Since then, Canada has become a leader among NATO countries in language and peacekeeping training in Poland, with hundreds of Polish officers and senior general staff having received training in Canada and Poland.

Further, Canada and Poland co-operate closely through multilateral initiatives as valuable partners in NATO, in Canada-EU relations and across a wide range of United Nations organizations and initiatives, including the International Security Assistance Force in Afghanistan.

With regard to academic relations, there are seven Canadian studies programs in Polish universities that conduct research, offer courses and organize conferences on Canada. Some have extensive library holdings and are a rich source of information for Polish students, researchers, academics and the general public.

Finally, Canada and Poland are also seeing rapid growth in our cultural relations. Canadian artists frequently entertain audiences in Polish cities.

Given our two countries' close ties, in 2009 two important agreements between Canada and Poland came into force: the social security agreement, which coordinates pension benefits between the two countries, and the youth mobility agreement, which allows youth from Canada and Poland to travel and work in the other country for up to one year.

In May 2012, during Polish Prime Minister Donald Tusk's visit to Canada, a new tax convention that will reduce tax barriers and encourage increased trade and investment between the two countries was signed.

This convention is a significant element of Bill S-17, which will further develop and facilitate Canada and Poland's mutual economic relationships and will eliminate double taxation with respect to taxes on income and on capital.

The impetus for the new convention with Poland, which was signed on May 14, 2012, was the need to replace the existing tax convention signed in 1987 in order to reflect current Canadian tax treaty policies.

The new convention will continue to contribute to the elimination of tax barriers to trade and investment between Canada and Poland and will help further solidify the economic links between us.

This convention remains consistent with the government's long-standing commitment to seek out new trade and investment opportunities for Canadians and to promote economic prosperity.

In addition to the close relationship Poland and Canada share, we also enjoy excellent trade relations. Poland is Canada's largest merchandise trading partner in central and eastern Europe. In 2011, the value of bilateral trade was $1.69 billion.

Canadian exports to Poland amounted to $251 million and included primarily machinery, electrical and electronic equipment, mineral ores, scientific and precision instruments and vehicles.

Canadian imports from Poland were valued at $1,439 million in 2011, with top sectors being machinery, furniture and bedding, aircraft and spacecraft products and electrical machinery.

EU membership, coupled with Poland's resilience during the recent global economic slowdown, makes it an attractive investment destination for Canadian companies.

Canadian cumulative direct investment in Poland totalled $411 million in 2011. Major Canadian investors in Poland include such companies as Pratt and Whitney Canada and Bombardier Transportation.

Hon. members, this convention also modernizes the income tax system between our two nations. Most countries, including Canada and Poland, tax their residents on their worldwide income. Moreover, when a resident of a particular country derives income from sources in another country, it is not uncommon for that other country to subject that income to tax.

The convention recognizes this international taxation dynamic and sets out under what circumstances and to what extent Canada and Poland may tax the earnings of one another's residents.

The convention also provides that when income, profits or gains may be taxed in both countries, the country of residence is to allow double tax relief against its own tax for the tax imposed by the country of source.

Specifically, the convention sets a maximum withholding tax rate of 5% for dividends paid to a company that holds directly at least 10% of the capital in the company that pays the dividends, and a maximum rate of 15% in all other cases.

The convention also generally limits to 10% the maximum withholding tax rate on interest and royalties. As well, the convention limits to 15% the maximum withholding tax rate on payments of pension income.

It includes a provision that limits the potential for double taxation arising from the application of Canada's taxpayer migration rules without restricting Canada's ability to tax its departing residents under pre-departure gains.

Finally, it includes the latest standard of the Organisation for Economic Co-operation and Development on exchange of tax information in order to assist Canadian tax authorities in the administration of Canadian tax laws.

In conclusion, trade and foreign investment are major engines of economic growth. Canada relies on open markets as a source of opportunity and a stimulus to efficiency, which in turn contributes to economic growth and rising incomes. Openness to trade, investment and global economic engagement are thus critical to Canada's long-term prosperity.

Bill S-17 is another step forward in ensuring the reduction of trade and investment barriers with our close ally, Poland. Considering the close relationship Canada and Poland have, it is only fitting that we ensure that our tax policies reflect the same mutual advantages. Further, Bill S-17 adds to Canada's low-tax commitment, ultimately allowing Canadians to keep more of their hard-earned money.

Since 2006, we have introduced more than 150 tax relief measures for Canadian families, individuals and businesses. The overall federal tax burden is the lowest it has been in 50 years. As a result, the average family of four now receives over $3,200 in extra tax savings. Going forward, we will continue to open markets and keep taxes low in pursuit of our main objective of increasing jobs, growth and long-term prosperity.

With that, I urge all members to vote yes on Bill S-17 and yes to closer Canada-Poland relations, stronger international trade relations and tax fairness.

[Matthew Dubé, NDP, Chambly—Borduas, QC]

Mr. Speaker, I thank my colleague for his speech.

He spoke at length about what Canada is doing abroad to combat tax evasion. We support this bill. It is important to note that this is an administrative bill, the kind that comes up intermittently to update various conventions signed with various countries.

The morning papers reported that Canada is not working with other countries to fight tax evasion. Many initiatives are in the works to do just that.

The member talked about the economic power of countries working together, free trade, information exchange and so on.

If those things truly matter to the government, can the member explain why it will not be participating in the efforts of the rest of the international community and why it will not be going beyond the administrative measures we support in this bill?

[Wladyslaw Lizon, Conservative, Mississauga East—Cooksville, ON]

Mr. Speaker, I think the hon. member's question goes way beyond the scope of the bill that we are debating here today. Actually, one of the aims of the bill and those tax treaties is to make sure that people cannot avoid taxes.

I suppose the hon. member understands that all these treaties were negotiated by teams from the respective countries over the years. They came to certain agreements. With the ratification of those treaties, we will move forward to make sure that there are no tax havens, that the information on taxation is exchanged and that residents of our countries would not be double-taxed and would not be subject to unfair taxation.

[Kevin Lamoureux, Liberal, Winnipeg North, MB]

Mr. Speaker, one of the things I made reference to when I had the opportunity to address the legislation was the fact that government needed to do more than just bring in the legislation, which is almost a given. One would expect the legislation that we have today.

Does the member not see the value or merit in giving additional resources to the Canada Revenue Agency so it can have the resources necessary to get tough with tax evaders? Does he not agree that would be a good step forward?

[Wladyslaw Lizon, Conservative, Mississauga East—Cooksville, ON]

Mr. Speaker, it is hard not to agree with the member and there is always a way to improve. We should all work together to ensure that everybody pays his or her fair share of taxes. That would include the members of the NDP caucus who chose not to participate and pay their fair share of taxes.

[Linda Duncan, NDP, Edmonton Strathcona, AB]

Mr. Speaker, before I speak, I would like to reply to my colleague's inappropriate statement.

Any Canadian has the opportunity to approach Revenue Canada and negotiate a payment of taxes over time, which is the situation here. It is time the Conservatives stop slurring hon. members of the House.

However, the issue here is the rising loss of revenue to the country by people who evade taxation. The member raised something very interesting. My colleague asked why the government did not go a step further, for example, along the lines of what the U.K. did with Switzerland. It reached an agreement where the U.K. could recoup up to 30% of the taxes that should have been paid to it.

When the government entertained these agreements, why did it not take a harder line in what should be included in the agreement? Do the Conservatives have a shopping list such that they have agreements with 999 countries, or are they actually seeking to improve the system of taxation so we can recover taxes and not have tax evasion in our country?