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 bill was last introduced in the 41st Parliament, 1st Session, which ended in September 2013.

Status

This bill has received Royal Assent and is now law.

Summary

This is from the published bill. The Library of Parliament often publishes better independent summaries.

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.

Elsewhere

All sorts of information on this bill is available at LEGISinfo, provided by the Library of Parliament. You can also read the full text of the bill.

Votes

June 10, 2013 Passed That, in relation to Bill S-17, 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, not more than five further hours shall be allotted to the consideration of the second reading stage of the Bill; and that at the expiry of the five hours provided for the consideration of the second reading stage of the said Bill, any proceedings before the House shall be interrupted, if required for the purpose of this Order, and, in turn, every question necessary for the disposal of the said stage of the Bill shall be put forthwith and successively, without further debate or amendment.

Tax Conventions Implementation Act, 2013Government Orders

June 10th, 2013 / 8:50 p.m.
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NDP

Mike Sullivan NDP York South—Weston, ON

Not that much, no.

Under the Conservative government, the uber-rich in Canada actually pay less as a percentage of the overall tax pie than they did in 2006. The people in the 1% are getting hit less and less and the rest of us, the 99%, the ordinary Canadians, the ordinary working people of our country, are paying more.

Tax Conventions Implementation Act, 2013Government Orders

June 10th, 2013 / 8:50 p.m.
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NDP

Mike Sullivan NDP York South—Weston, ON

That is completely unfair. This legislation does not actually deal with that, but it does deal with the notion of taxes, taxes that should be fair and should be treated fairly. People should not be doubled taxed. Yet the woman and her son in Calgary are being double taxed because they will pay tax in the U.S. that they did not have to pay in Canada, which is not fair.

There is also spectre of the government now deciding that it is going to use technology, as the member for Don Valley East suggested, to go after the tax cheats. I had a phone call from a constituent just last week when he heard about the great tax cheats out there who made the mistake, he thinks, of writing to the Prime Minister because shortly after that he was audited. This is a senior on a fixed income.

That audit determined he owed $80 from three years ago. He got a letter from Revenue Canada saying that if he did not pay that $80, he could go to jail for five years. If he agreed with the CRA, he could pay the $80, he would be fined and maybe not have to go to jail, but if he disagreed, he certainly would go to jail. That is what he thought was going to happen. He ended up paying the $80 and a $150 fine. Why are we going after this little fish in this big fish pond? There are so many more people who are evading taxes by so much more than that. By spending the resources to go after a poor senior who apparently did not pay $80 three years ago is doing ourselves a disservice.

Tax Conventions Implementation Act, 2013Government Orders

June 10th, 2013 / 8:55 p.m.
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Conservative

Phil McColeman Conservative Brant, ON

Mr. Speaker, listening to the member's speech and knowing the party he represents is quite interesting. He talks about the notion of tax cheats, people who do not pay their taxes. The NDP knows that full well because there are members of its caucus, one being the critic for this very file, who have not paid their taxes. When he puts those people in that category, he is putting his own colleagues in that category. They are members of the House of Commons who have not fessed up and the Leader of the Opposition has not taken any action at all to ask those people to pay their taxes back and remove themselves from the party while they do that. We have heard nothing.

What is the member's opinion of that cheat situation?

Tax Conventions Implementation Act, 2013Government Orders

June 10th, 2013 / 8:55 p.m.
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NDP

Mike Sullivan NDP York South—Weston, ON

Mr. Speaker, it is one thing to park money offshore and avoid taxes, but it is quite another situation for individuals such as those the member referred to, who are in fact paying their taxes.

There was a dispute, and they are paying the taxes. There is no question that the money is getting paid.

Ordinary working Canadians are paying taxes. These people are paying taxes, as any ordinary working Canadian could and should. The issue is not that; it is that the $29 billion that is not being paid to our treasury would go a long way toward alleviating some of the difficulties the government is in after losing track of $3.1 billion.

Tax Conventions Implementation Act, 2013Government Orders

June 10th, 2013 / 8:55 p.m.
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Liberal

Jim Karygiannis Liberal Scarborough—Agincourt, ON

Mr. Speaker, I wonder if my colleague would share his views on the taxes that should have been paid by former Conservative prime minister Brian Mulroney when he took the $300,000 and put it in the safe.

I wonder if he would also like to comment on whether Senator Mike Duffy should also be paying taxes on the $90,000 present that he got from the Prime Minister's Office.

Tax Conventions Implementation Act, 2013Government Orders

June 10th, 2013 / 8:55 p.m.
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NDP

Mike Sullivan NDP York South—Weston, ON

Mr. Speaker, there are always good questions from that corner.

When a former prime minister admits to pocketing $300,000 in cash and not paying taxes on it until many years later, it calls into question some of what our tax system is all about.

The people being complained about are apparently not avoiding taxes, because eventually they paid it. The same is true of Mr. Duffy. If Mr. Duffy has received money in the form of a gift that he has not reported to the tax department, there are serious consequences.

Tax Conventions Implementation Act, 2013Government Orders

June 10th, 2013 / 8:55 p.m.
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NDP

Niki Ashton NDP Churchill, MB

Mr. Speaker, my colleague referred in his speech to the government's general doublespeak on issues, including tax fairness, and I would like to read into the record something that connects to the points he raised. It was said by Dennis Howlett, from the Canadians for Tax Fairness organization:

...the capacity of the CRA to go after tax cheats using tax havens needs to be increased significantly. While tax havens will require a concerted international effort, there is much more that Canada could be doing itself. The CRA internal audit document revealed that tax practitioners believe the CRA is not doing enough to catch or prosecute tax evaders.

Here we have a government that claims to be tough on tax fairness, when in fact we are hearing about significant cuts to the CRA and an inability to deal with the real issue of tax evasion and taxes being directed toward tax havens.

Could my colleague speak to that?

Tax Conventions Implementation Act, 2013Government Orders

June 10th, 2013 / 8:55 p.m.
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NDP

Mike Sullivan NDP York South—Weston, ON

Mr. Speaker, cutting CRA at a time when the Auditor General says there is $29 billion out there that needs to be collected is a very strange move indeed.

If a government finds that there is money to be collected, it should increase the size of the tax-collecting agency and actually go after the very people who are hiding this tax.

The money in offshore bank accounts is not the money of ordinary working Canadians. It is not from the person running a mom-and-pop store on the corner of a street in Winnipeg or from people who are working for a living by putting in plumbing; it is from those with the ability and the wherewithal to hide money offshore.

Those are people much richer than you or I. Those are the people who are able to hide money, and we are allowing it to happen. The government ought to be spending a whole lot more money on the CRA to make sure those kinds of things stop happening.

Tax Conventions Implementation Act, 2013Government Orders

June 10th, 2013 / 9 p.m.
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Conservative

Ed Komarnicki Conservative Souris—Moose Mountain, SK

Mr. Speaker, it gives me pleasure to rise today in the House to speak to Bill S-17 the tax conventions implementation act, 2013, at second reading. This is technical legislation that would implement Canada's recently concluded tax treaties with Namibia, Serbia, Poland and Hong Kong, as well as tax agreements with Luxembourg and Switzerland.

The conversation has gone far and wide and far beyond the extent of the treaties and what we are discussing today with respect to the legislation itself.

Bill S-17 is part of Canada's ongoing efforts to update and modernize its network of income tax treaties with other countries, which is one of the most extensive of any country in the world.

Canada has comprehensive tax treaties in place with 90 countries, and our government is hard at work on agreements with other jurisdictions in connection with tax evasion, if we want to call it that. The double taxation that we spoke of relates to occurrences between countries and to movements of income, capital and properties between countries.

I want to make it clear that Bill S-17 does not represent any new or significant change in policy and should be considered standard and routine, but very important, legislation. In fact, tax treaties covered by this bill, like their predecessors, are patterned on the OECD model tax convention, which is accepted by most countries around the world. The pattern has been set, and these treaties are negotiated along that line.

As respected international tax commentator Jeffrey Owens, current senior policy adviser at Ernst & Young and former director for tax policy at the OECD, has noted, “Quite simply, the OECD model has established itself as the means of settling the most common problems that arise in the field of international taxation”.

Once again I would remind members we are talking about international taxation and not taxation within the country and the residents of that country itself. Therefore, it goes without saying that the provisions in these particular treaties comply with international norms and are based on standards that are generally acceptable.

The tax treaties in this bill have been designed with three goals in mind.

The first is to prevent double taxation and provide a level of certainty about tax rules that will apply to particular international transactions. That is important. Every business wants to know what the rules are. Businesses want to have a measure of certainty and know what to expect, and of course we want to do away with double taxation to ensure that appropriate investments take place.

The second goal is to prevent avoidance and evasion of taxes in various forms of income flows between the treaty partners. If the income flow is simply done to avoid tax, it needs to be dealt with.

The third goal is to facilitate international trade and investment, both incoming and outgoing.

These goals are consistent with the findings of the 2008 report of the advisory panel on Canada's system of international taxation, convened by our government to make recommendations to enhance Canada's international tax advantage. Not only is Bill S-17 consistent with the findings of that report, but the panel's observations helped clarify the importance of today's legislation for the Canadian economy. This allows for investment to take place, it allows for jobs to be created, and it allows for the long-term prosperity of Canada.

According to the report:

Canada's system of international taxation is important to our country's competitiveness. At the global level, competitiveness is crucial to attracting high-value activities, spurring innovation, and creating skilled jobs. ... Improving the international tax system will enhance Canada's advantage to the benefit of all Canadians.

I will speak further about this legislation's specific objectives, but first I would like to highlight how the tax treaties help contribute to a competitive tax system in Canada.

As members will know, our government is committed to expanding Canada's network of tax agreements with other countries. Better transparency and information exchange for tax purposes are critical to ensuring that Canadian taxpayers report their income earned from all sources and pay the right amount of tax in Canada.

We are serious about combatting tax evasion through the negotiation of tax treaties and tax information exchange agreements, sometimes known as TIEAs.

Since 2007, our government has brought into force 16 such agreements, signed three others and is actively negotiating with 11 other jurisdictions, including negotiations launched last year with Panama. Not only that, but we have provided the Canada Revenue Agency with even more tools to conduct international tax audits and enforcement.

As a direct result of action taken by our government, Canada continues to contribute actively to the efforts of both the OECD global forum on transparency and exchange of information and the G20, in order to further support the effective implementation of the OECD standard by all jurisdictions.

Our government understands the importance of open markets and full participation in the global economy and has shown continued leadership on the world stage by opposing protectionism and trade-restrictive measures. Canada believes open markets create jobs and economic growth for people around the world.

Indeed, the advisory panel identified the importance of trade as a key driver in improving Canada's system of international taxation. As the report noted:

Cross-border business investment has become central to the world economy. Global two-way trade is important to Canada’s prosperity, as it is to that of other countries. New competitors are emerging, notably from developing economies. ... Canadian businesses need to be able to compete with them for investment on both the outbound and inbound fronts.

To support Canadian business investment abroad, attract foreign business investment at home, and strengthen our open economy, tax policy must keep pace with global trends.

Our government strongly supports cross-border trade and investment, but we must ensure that cross-border investment is not used to avoid taxes with complicated tax schemes. In this spirit, the advisory panel identified a type of cross-border transaction, generally referred to as “foreign affiliate dumping”, as being abusive. These kinds of transactions reduce the Canadian tax base without providing any significant economic benefit to Canadians and need to be dealt with by legislation.

The panel recommended that a targeted measure be introduced to curtail these transactions while ensuring that legitimate transactions are not affected.

Foreign affiliate dumping transactions often involve a Canadian subsidiary using borrowed funds to acquire shares of a foreign affiliate from its foreign parent company.

Consistent with the advisory panel's recommendation, economic action plan 2012 announced rules to curtail foreign affiliate dumping transactions while at the same time preserving the ability of Canadian subsidiaries of foreign parents to undertake legitimate expansions of the Canadian-based businesses.

What we are trying to do is set the rules to ensure that people pay the tax they ought to pay and are not double-taxed, but also that they are not using means or mechanisms to create expenses or obviate income so that they do not have to pay taxes.

The new foreign affiliate dumping rules, where certain conditions are met, deal with deemed dividends to be paid by a Canadian subsidiary to its foreign parent to the extent of any debt funding incurred by the Canadian subsidiary, or other non-share consideration given by the Canadian subsidiary, for the acquisition of the shares of a foreign affiliate. Any dividend that is deemed a dividend in that fashion would be subject to non-resident withholding tax, which would generally be reduced to 5% of the gross amount of a dividend by an applicable tax treaty.

Going forward, our government will continue to monitor developments in this area to determine whether further action is required.

Now I will return to the measures contained in the legislation before us today and speak further to the importance of tax treaties, a vital part of the government's overall approach to improving the tax system. Indeed, they are an integral element of our economic action plan to bring jobs, growth and long-term prosperity to all Canadians.

Tax treaties like those in Bill S-17 directly affect cross-border trade in goods and services with our tax treaty partners, which in turn impacts Canada's domestic economy. In fact, over 40% of Canada's annual GDP can be attributed to exports. Moreover, Canada's economic wealth each year also depends on foreign direct investment as well as inflows of information, capital and technology.

In other words, the tax treaties contained in Bill S-17 would benefit Canadian businesses and individuals with operations and investment in the countries covered by this legislation, not only for their investments abroad but also for those investments that come into our country and bring all of what I mentioned with them.

Not only that, but tax treaties foster an atmosphere of certainty and stability for investors and traders that can only serve to enhance Canada's economic relationship with each country.

Another important aspect of these treaties is that they include a mechanism to settle problems encountered by taxpayers, in particular when double taxation arises. It is very important that if there is a dispute, there is a way to settle it, and there is provision in these agreements as to how that might happen, not only with respect to the taxpayer but also with the two countries involved as well. Under this mechanism, taxpayers can bring to the attention of taxing authorities issues that arise from the interaction of our tax system with that of the other treaty partner and seek a resolution to the issue.

Eliminating administrative difficulties and unnecessary tax impediments is an important priority for the Government of Canada and an important component of international tax treaties. In short, these treaties will provide individuals and businesses in Canada and other treaty partner countries with predictable and equitable tax results in their cross-border dealings, which can bring only positive outcomes for the Canadian economy.

As is common for tax treaties legislation, Bill S-17 would address double taxation issues, which occur internationally when two or more countries impose taxes on the same income for the exact same time period. Obviously that can happen, given the tax regimes of each country, and when it does, it needs to be dealt with. This would obviously be extremely unfair. Double taxation is not something that anyone would like and no parliamentarian would endorse, except, perhaps, the NDP, which is interested in spending and taxing on just about everything, not to mention the $26-billion carbon tax.

Addressing this issue, it is an non-partisan one. It is very common for tax treaty legislation. I want to underline that by reading verbatim from a speech given by the current member for Scarborough—Guildwood, who was the parliamentary secretary to the minister of finance under the former Liberal government in 2004. I will quote at some length, because I think he establishes the premises of why these treaties are as important as they are. He said:

The first, and probably the most important, objective of tax treaties is to avoid double taxation and provide a level of certainty about the tax rules that apply to international transactions.

Again, I want to re-emphasize that we are talking about international transactions. The member continued:

Relief from double taxation is so very necessary and deserves to be discussed in some detail. The potential arises when a taxpayer lives in one country and earns income in another. Without a tax treaty, both countries could claim tax on the income without providing the taxpayer with any measures of relief for the tax paid in the other country. This is simply unfair.

To alleviate the potential for this happening, a tax treaty between the two countries allocates taxing authority with respect to a given item of income in one of three ways: first, the income may be taxed exclusively in the country in which it arises; second, it may be taxed in the country in which the taxpayer resides; or, it may be taxable in both the source country and the residence country, with relief from double taxation provided in some form, usually the country of residence.

The member was saying that there are a lot of factors at play and we want to establish that these are the rules of the game. If a person earns income, he or she will be taxed only once, in one place, by one country and if that does not happen, here is the mechanism that can correct that.

I also want to speak about withholding taxes, because a lot of this deals not only with earning income, but with dividends, the disposition of shares, the disposition of capital property and so on. Another way to ensure that double taxation does not exist is to lower or reduce something called "withholding taxes". This is another common feature of tax treaty legislation. Obviously, it can be burdensome, with a lot of red tape and hassle, not to mention tying up huge sums of money by virtue of withholding.

These taxes are levied in one country on a certain income earned in that country and are paid to residents in another country. Again, I am quoting from the member for Scarborough—Guildwood from when he was the parliamentary secretary to the minister of finance under the formal Liberal government, who said:

Withholding taxes are a common feature of the international taxation system. In Canada's case, they are levied on certain payments that Canadian residents make to non-residents. These payments include interest, dividends and royalties, for example. Withholding taxes are often levied by a country on the gross amount of certain types of income paid to non-residents and such taxes normally represent the non-resident's final obligation with respect to income tax payable in that country with respect to that particular income.

There are obligations in the other country, there is withholding tax here, usually equally to what might be paid over there, when there are fairly large amounts of money being held. Tax treaties are important because they reduce the rates of withholding taxes and help to avoid double taxation.

Specifically with regard to Bill S-17, the treaties with Namibia, Serbia, Poland and Hong Kong provide for a maximum withholding tax on dividends between the affiliated companies at 5%. In respect to all other dividends, the treaties in Bill S-17 provide for a rate of withholding tax set at 15%. I should note that reductions also apply in respect of interest and royalties.

Our government is working with other countries to address the problem of double taxation. Another problem it is working on is to address tax evasion and avoidance, both tremendously unfair and steps that are harmful to our economy. The loss of revenue resulting from tax avoidance and evasion has the potential to adversely affect the efforts of governments in reaching important policy objectives.

Of course there will be certain sharing of information between the countries with respect to tax evasion, and that will help. Not only that, but tax evasion obviously places a disproportionate share of tax burden on honest taxpayers as has been mentioned in the House here earlier today. The government recognizes that one key component of the defence against international tax avoidance and evasion is through improved and expanded mechanisms for international co-operation and information sharing.

To facilitate that goal, treaties like those found in Bill S-17 permit the exchange of tax information between revenue authorities in accordance with standards developed by the OECD, and in doing so help them to identify cases of tax avoidance and evasion, and to act on them.

In conclusion, I would like to remind all members that Bill S-17 is not controversial, nor does it contain any surprises or contentious issues. There is little doubt that its benefits are clear. The treaties covered in this proposed legislation will promote certainty, stability and a better business climate for taxpayers and businesses in Canada and in these treaty countries.

Moreover, these treaties will help to secure Canada's position in the increasingly competitive world of international trade and investment. They comply with international OECD standards and will help ensure a stronger tax system for Canadians. They will help ensure our goal of tax fairness for Canadians.

They provide the rules of the road for foreign investment, for foreign movement of capital and income. This is something that investors and business would expect Parliament to deal with. It is important that Parliament deals with it at this stage, because the take-effect date is someplace down the road. We would like to see this particular legislation passed into law before the summer break.

I would ask all members to support this legislation.

Tax Conventions Implementation Act, 2013Government Orders

June 10th, 2013 / 9:15 p.m.
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Liberal

Kevin Lamoureux Liberal Winnipeg North, MB

Mr. Speaker, the idea behind the legislation is positive. I have made comment on that. It has the support of the Liberal Party.

However, one of the things that we need to acknowledge right up front is that times are changing rapidly. There is so much more that the government could and should be doing to combat tax evasion. One of the things is to look at more of a multilateral approach based on information and the sharing of information. This would go a long way in dealing with the issue, more so than bilateral agreements that have been more of the norm but which I believe are nowhere near as effective.

My question to the member is, what does he feel the government should be doing in regard to the whole multilateral approach, and the issue of providing financial resources so that CRA has the ability to actually enforce this legislation?

Tax Conventions Implementation Act, 2013Government Orders

June 10th, 2013 / 9:15 p.m.
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Conservative

Ed Komarnicki Conservative Souris—Moose Mountain, SK

Mr. Speaker, there is always the opportunity to do more. Obviously we need more legislation. However, it is important to pass the legislation that is before us that specifically deals with the countries outlined in it. As I mentioned before, these tax agreements have been signed with over 90 countries. The OECD has set sort of a pattern of what these tax treaties should look like, and the kind of rules of the road that should be incorporated and that most countries have started to adopt.

Obviously there will be an increase in the number of treaties that are being signed, and I think we need to continue pursuing them and pursuing them actively. More could always be done, but for now this is the treaty that is before the House. It has been negotiated. It is a positive thing that business would like to see passed. It is important that this particular government does that.

Additionally, and contrary to what has been said here, there have been significant investments targeted with respect to the enforcement provisions and the seeking out provisions that CRA may have with respect to international investments.

Tax Conventions Implementation Act, 2013Government Orders

June 10th, 2013 / 9:20 p.m.
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NDP

Mike Sullivan NDP York South—Weston, ON

Mr. Speaker, my colleague did not deal with the issue of the failure of some of the existing tax treaties to deal with the changes in Canadian tax law. For example, the tax-free savings account is not part of what is reciprocated in the U.S. so people who have to pay U.S. taxes have to pay on any money that they invest in a tax-free savings account in Canada.

However, of more concern to me as the deputy critic for persons with disabilities is the disability tax credit, which is not available to those people who file taxes in both Canada and the U.S., who live in Canada, whose children live in Canada but who, by reasons of the U.S. government, are deemed to be U.S. citizens. As a result, those individuals are paying tax twice. I would think that the Conservative government would be working hard to try to resolve the issue of double taxation with our biggest trading partner, the United States.

I would ask the hon. member what the government intends to do about that.

Tax Conventions Implementation Act, 2013Government Orders

June 10th, 2013 / 9:20 p.m.
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Conservative

Ed Komarnicki Conservative Souris—Moose Mountain, SK

Mr. Speaker, I would remind the member that this tax treaty deals with Namibia, Serbia, Poland, Hong Kong, Luxembourg and Switzerland. That is the legislation we are discussing. That is the legislation that needs to be passed. The member should look at it and read the bill as it applies to all these countries to see if there is are improvements, changes or amendments to make. If he supports it, he should support it.

With respect to the United States, it is nowhere in this document. It has nothing to do with this bill. I agree that there are probably a lot of issues that need to be dealt with between the two countries that I am sure are being looked at by the various levels and will be dealt with. However, that is not what we are talking about today, which is this particular legislation and ensuring that the rules of the road are understood by the parties of both countries.

I might also add that the OECD has set out what it thinks it should be. Basically, this ties into that. There should be more of these happening, notwithstanding there are other issues that need to be addressed as well.

Tax Conventions Implementation Act, 2013Government Orders

June 10th, 2013 / 9:20 p.m.
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Green

Elizabeth May Green Saanich—Gulf Islands, BC

Mr. Speaker, my question for the member for Souris—Moose Mountain is this.

I am well aware that we are here tonight to debate Bill S-17 and that it deals with tax treaties. I have not heard a single member of this place suggest that they do not want to vote for it. I find it strange that on a treaty and a bill of no consequence, which everyone supports, we have time for debate and we have committee hearings, but on something that threatens the sovereignty of Canada, such as the Canada-China investment treaty, we have neither had hearings nor adequate time for debate.

Would my hon. friend from Souris—Moose Mountain like to join me in urging that we still have time for debate before that treaty is ratified?

Tax Conventions Implementation Act, 2013Government Orders

June 10th, 2013 / 9:20 p.m.
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Conservative

Ed Komarnicki Conservative Souris—Moose Mountain, SK

Mr. Speaker, I might remind the member that soon we will be off on summer break so time will be short.

To say that this treaty is of no consequence surely must mean the member has not read the legislation or has not listened to business, because business is quite clear. It wants this agreement. It wants to know what the rules of investment are. Billions of dollars are transferred that create jobs and long-term prosperity in both countries. Therefore, it is important that we deal with the legislation here today and that members are given the opportunity to debate this.

If we had said that members do not have the opportunity to debate this particular tax treaty, I cannot imagine what the member might have said. Perhaps, “We must have the time to debate it.” We have provided the time to debate it and the member talks about something else.

I know there are a lot of other issues and a lot of other pieces of legislation. However, today we are dealing with this legislation. If the member wants to debate she should debate this legislation, not something else.

So far what I have heard from the opposition is a debate on all kinds of other issues that may be of some significance but nothing to do with the tax treaties. If you want time to debate, when time to debate is given, debate the issues before you and not something else.