Multilateral Instrument in Respect of Tax Conventions Act

An Act to implement a multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting

This bill was last introduced in the 42nd Parliament, 1st Session, which ended in September 2019.

Sponsor

Bill Morneau  Liberal

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 a multilateral instrument in respect of conventions for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
The multilateral instrument is an international treaty developed as part of the G20 and OECD’s project to tackle base erosion and profit shifting (BEPS). The purpose of the multilateral instrument is to modify, in their application, tax conventions between two or more parties to the multilateral instrument so as to further the objectives of the tax convention. The multilateral instrument operates alongside tax conventions to modify them in their application; it does not directly modify the text of the tax conventions. The multilateral instrument will apply to a Canadian bilateral double tax convention only if both parties to the convention notify the depositary that the convention is intended to be covered by the multilateral instrument. The Secretary-General of the OECD is the depositary of the multilateral instrument. The implementation of the multilateral instrument requires the enactment of this Act.

Elsewhere

All sorts of information on this bill is available at LEGISinfo, an excellent resource from the Library of Parliament. You can also read the full text of the bill.

Votes

April 8, 2019 Passed Concurrence at report stage of Bill C-82, An Act to implement a multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting

February 28th, 2019 / 12:20 p.m.
See context

NDP

Pierre-Luc Dusseault NDP Sherbrooke, QC

You justify Bill C-82 by saying the new provisions will be more effective in combating abuses than the present act.

February 28th, 2019 / 12:20 p.m.
See context

NDP

Pierre-Luc Dusseault NDP Sherbrooke, QC

Can you confirm what you previously said, that it's possible for taxpayers to abuse the present tax conventions—hence Bill C-82—to avoid their Canadian tax obligations?

February 28th, 2019 / 12:15 p.m.
See context

NDP

Pierre-Luc Dusseault NDP Sherbrooke, QC

Thank you, Mr. Chair.

Last week, I believe, I asked an expert from outside the department a question, and I think it would be worthwhile to put it to the Finance Department representatives today.

Gentlemen, since everyone here's already up to speed on the issue, there's no need to confirm today that the new international convention contemplated in Bill C-82 has to be ratified by the partner countries in order to come into force. Every country has to follow the necessary legislative process as we are doing. Does that implicitly mean that, if a country fails to ratify the convention within a few months or years, the former convention will apply to that country?

February 28th, 2019 / 12:15 p.m.
See context

Liberal

The Chair Liberal Wayne Easter

We shall reconvene.

Pursuant to the order of reference of Monday, October 15, 2018, we're dealing with Bill C-82, an act to implement a multilateral convention to implement tax treaty-related measures to prevent base erosion and profit shifting.

We have with us, as witnesses from the Department of Finance, Mr. Trevor McGowan, who is the Director General, Tax Legislation Division, who has been with us many times before; and Mr. Boychuk, Expert Adviser, Tax Legislation Division.

I understand that you're here basically to answer questions. You don't have an opening statement.

On Bill C-82, on which we've had a number of witnesses before the committee, are there any questions for the witnesses from the Department of Finance before we go to clause-by-clause consideration?

Mr. Dusseault.

February 28th, 2019 / 12:05 p.m.
See context

Liberal

The Chair Liberal Wayne Easter

With that, we will have to go to our next session.

On behalf of the committee, I want to thank you, Mr. Hamilton, and all the other witnesses who came with you, for providing the information you did.

We will suspend for two minutes and ask Mr. McGowan and Mr. Boychuk to come forward on Bill C-82.

Canada–Madagascar Tax Convention Implementation Act, 2018Government Orders

February 27th, 2019 / 4:15 p.m.
See context

Conservative

Jamie Schmale Conservative Haliburton—Kawartha Lakes—Brock, ON

Mr. Speaker, I was just paying attention to the testimony going on at the justice committee. If people are watching at home, I suggest they turn to that and watch the testimony by the former attorney general. It is quite rivetting. I will not take offence if my words get missed.

It is my pleasure to speak to Bill S-6, an act to implement the convention between Canada and the Republic of Madagascar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. In November of 2016, the convention was signed between the governments of Canada and Madagascar. While reviewing the bill, I was surprised to learn that we have had diplomatic relations with Madagascar for nearly 55 years.

In terms of economic activity between our two countries, Canada imported $100 million in goods last year. The bulk of these imports were mineral and vegetable products. Madagascar imported $16 million of Canadian goods last year. Global Affairs Canada reports that Canadian direct investment to Madagascar was $28 million in 2017. Canada has mining companies there. We do business with Madagascar.

Since 1976, Canada has entered into similar tax agreements with countries all around the globe. In fact, we currently have 93 such agreements in place. The main purpose of the convention is to eliminate double taxation and prevent international tax evasion.

I want to support Bill S-6 and the international efforts coordinated by the organization for Organisation for Economic Co-operation and Development aimed to reduce treaty shopping for tax havens. However, the bill reminds us that the government's overall approach to addressing international tax evasion is inadequate and more needs to be done.

I had the pleasure of rising in the House on September 28 of last year to speak to Bill C-82, an act to implement a multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting. For the benefit of those at home and as a reminder to my colleagues in the House, Bill C-82 aims to make it more difficult for corporations to hide money in offshore tax havens.

What is double taxation? It is a taxation principle referring to income taxes paid twice on the same amount of earned income. It could occur when income is taxed at both the corporate level and the personal level. It also occurs in international trade when the same income is taxed in two different jurisdictions.

I had a number of concerns with Bill C-82. I will not repeat them all here, but one of my major concerns, which is an underlying problem with these agreements, is this. I really have no problem with the agreements that inevitably make other jurisdictions more attractive to Canadian investment. Promoting investment in Canada should be a priority for the federal government, but in truth we live in a global community with economic opportunities for Canadians outside the country, whether through direct investment or indirectly through mutual or pension funds.

What I see as a problem is when the government fails to support competitively lower taxes for Canadians and businesses domestically. With respect to businesses, we need to lower corporate taxes, reduce red tape and create an investor-friendly climate. This is something we must do in concert with bills like Bill C-82 and Bill S-6.

We have companies moving from Canada to the United States because of a lower corporate tax regime. If we want to stop the use of tax havens, we need to make it attractive to invest at home and make tax rates competitive with other jurisdictions. The more investment dollars we can attract and retain in Canada, the less taxes we need to spend in pursuit of those who exploit loopholes in tax rules.

Let me be clear. The Conservatives support measures to crack down on tax evasion. Aggressive tax avoidance is a major source of lost tax revenue for high tax jurisdictions like Canada. The vast majority of citizens and businesses in Canada pay their taxes and follow the rules. We need a competitive and fair tax system for all Canadians and corporations that do business in Canada. That is fundamental to a healthy and equitable economy.

During the fall economic statement, the Minister of Finance confirmed that the Liberals were borrowing about $18 billion this year and almost $20 billion next year to pay for their spending, and they have no plan to balance the federal budget. This year's deficit is more than three times what the Prime Minister said it would be. He has added $60 billion in debt.

We are giving the impression to Canadians, through bills like Bill S-6, that the Liberal government is more interested in hunting down tax evaders in Madagascar, although I am not aware of an outbreak of tax evaders in Madagascar, than creating a fair and equitable system here in Canada.

Canadians know that one does not need to be an economist to understand that more debt today means higher taxes tomorrow. Tax treaties might be important, but something that is far more important is the halting of the ongoing plundering of our children's economic futures.

Canadians are going to pay higher taxes once the government's Canada pension plan tax increases are fully implemented by 2025. That is up to $2,200 per household. The Prime Minister's national carbon price, the carbon tax, will cost up to $1,100 per household. Canadians are going to pay more in future taxes to service the interest on the government's ballooning deficit fuelled by out-of-control spending.

The Liberals' previously proposed tax grab would have forced business owners in Canada to pay 73% on savings income, penalized family businesses for sharing earnings and work with family members and doubled the tax on the sale of a farm from parents to children, forcing them to sell to multinational corporations instead.

This is not how we create a friendly investment climate in Canada. This is not how we create wealth and lift people out of poverty. This is not how we safeguard our children's future.

The previous Conservative government signed tax agreement's like Bill S-6, but we did this in concert with reducing taxes for Canadian families and businesses. The average Canadian middle-class family is paying $800 more income tax today than it did before the Liberal government took office in 2015.

The Conservatives implemented family tax cuts, arts and fitness tax credits and education and textbook credits, all of which were cancelled by the government.

Bill S-6 is more than just about cracking down on tax evaders. Trade and commerce between two countries are supported by these agreements. That is why our previous Conservative government signed a record number of them.

Under the previous Conservative government, Canadian workers and businesses won free trade access to more than 50 countries around the world, creating hundreds of thousands of jobs and opportunities for everyone. In just three years, the Prime Minister has failed to secure a trade deal with China and delayed and nearly derailed plans for Canada to join the CPTPP trade agreement.

Worst of all, the Prime Minister made massive concessions to the United States at the NAFTA negotiation table. He backed down on cars, giving the U.S. limits on how many cars we could export. He even backed down on pharmaceuticals, giving the U.S. higher profits at the expense of Canadians from coast to coast to coast. Canadians cannot bid on American government contracts and we still have tariffs on steel, aluminum and softwood lumber, with no timeline to end them.

Bills like Bill S-6 are important and need to be supported. Tax evasion is a real issue. We need to crack down on tax evasion, but we also need to support lower taxes for Canadian businesses. We have lost out on tens of billions of dollars' worth of investment because of the government's misguided fiscal policies.

Investment is fleeing, we are losing jobs, families are worse off than they were before and we are going in the opposite direction with respect to what most countries are doing by lowering taxes and making themselves investment magnets.

Canada–Madagascar Tax Convention Implementation Act, 2018Government Orders

February 27th, 2019 / 4:15 p.m.
See context

Liberal

Francesco Sorbara Liberal Vaughan—Woodbridge, ON

Mr. Speaker, I thank the member from Quebec for his question. I would like to answer in French, but it is a bit tricky.

Our government has invested over $1 billion in the CRA to provide the wonderful folks who work there with the services and tools they need to ensure that all Canadian organizations, including multinationals, pay their fair share of taxes.

Our government is working extremely well with our international partners to ensure that tax avoidance, because there is a difference between tax avoidance and tax evasion, is brought down, that we ensure corporations and high net worth individuals do not take advantage of loopholes. We are closing loopholes. We are investigating. Most important, we have the right tools to do such a thing and CRA and its associate partners have those tools. This will be very effective with Bill C-82, base erosion profit shifting.

We all know that under 10 years of the former government, under the Harper regime, that money was cut from the CRA and it was unable to do its job effectively and diligently for hard-working Canadians, much like the ones in my hon. colleague's riding, who I was able to serve with on the finance committee, and those wonderful Canadians in my riding of Vaughan—Woodbridge.

Canada–Madagascar Tax Convention Implementation Act, 2018Government Orders

February 27th, 2019 / 4:10 p.m.
See context

NDP

Pierre-Luc Dusseault NDP Sherbrooke, QC

Mr. Speaker, I thank my colleague for his speech and many interventions at the Standing Committee on Finance. I know that he is very knowledgeable about his files, especially tax conventions and double taxation agreements, which aim to help our corporations be successful and to ensure tax fairness for corporations that do business abroad.

With Bill C-82, the government hopes to revise all our tax conventions because public officials have indicated that some taxpayers abuse them. I know that my colleague is very conversant with Bill C-82 as well.

Would he also acknowledge in the House that, absent the changes provided for in Bill C-82, our tax conventions are being abused by certain Canadian taxpayers in order to avoid paying their fair share of Canadian taxes?

Canada–Madagascar Tax Convention Implementation Act, 2018Government Orders

February 27th, 2019 / 3:50 p.m.
See context

Liberal

Francesco Sorbara Liberal Vaughan—Woodbridge, ON

Mr. Speaker, it is great to be here this afternoon. Bill S-6 is along the lines of what our government's platform and agenda has been over the past three and a half years. The bill fits well within our tax treaties with our international partners and international organizations. It is a routine bill, a routine tax convention, which we need to have implemented.

If I may, I will take a step back in terms of what our government has done over the last three years with regard to improving our tax system, investing in the CRA and investing in middle-class Canadians. Yesterday we had Statistics Canada report to us on the annual Canadian Income Survey, 2017. As an economist by training and someone who reads the daily notices from Statistics Canada, it was wonderful for me to see this report. It was wonderful to know that from the work we have been doing for three years, not only have 900,000 jobs been created by hard-working Canadians and Canadian entrepreneurs but also that the growth that has occurred is inclusive, widespread and benefiting Canadian families from coast to coast to coast, including families and their children in my riding of Vaughan—Woodbridge. It was great to see that over 850,000 Canadians have been lifted out of poverty.

We based our platform three years ago on the Canada child benefit, which benefits nine out of 10 Canadians. It is tax free, simple and monthly. We based it on cutting taxes for nine million middle-class Canadians, which benefits them and their families. We also asked the 1% of Canadians, the wealthiest, most fortunate in our country, to pay a bit more. Now we see the fruits of those results, which have lifted hundreds of thousands of Canadians and their families out of poverty.

We ran on a platform of strengthening the middle class and helping those working very hard to join the middle class. I am happy to say that we are getting there. We have seen our poverty rate decline significantly. We know we have more work to do.

We have seen tens of thousands of seniors now being lifted out of poverty. That 10% increase in the guaranteed income supplement for our most vulnerable seniors is benefiting my riding and the 17,810 seniors who, according to Statistics Canada, live in my riding of Vaughan—Woodbridge. I know that 1,530 of those vulnerable seniors in my riding received, on average, $800 more every year from the 10% increase in the guaranteed income supplement we campaigned on, that we promised and that we implemented.

I look at this Canada–Madagascar tax convention bill, Bill S-6, as another step forward in improving our tax treaties with our international partners and in building a stronger Canada by ensuring that all Canadians pay their fair share of taxes and that all Canadians can depend on the services that we, as a government, deliver. When I say we, I mean all members of Parliament.

Over the past three years, we have taken action on multiple fronts to ensure that this happens, because when everyone pays his or her fair share, the government can continue to deliver the programs and services Canadians need while keeping taxes low for middle-class families. Again, I allude to the fact that we cut taxes for nine million Canadians, as we promised at the outset. Promise made, promise kept.

As members know, one of the government's first actions was to cut taxes for middle-class Canadians. Over nine million Canadians are now benefiting from this change, with nearly $20 billion over five years of tax relief for families from coast to coast to coast. To help pay for this middle-class tax cut, we asked the wealthiest to pay a little bit more.

Next we made changes to better provide targeted, more generous and simpler support for Canadian families with children. We accomplished this with the introduction of the Canada child benefit, or the CCB, which was implemented, proudly, on July 31, 2016.

In my riding of Vaughan—Woodbridge, in looking at the numbers for one of the time periods, I see that nearly 17,000 children benefited, and 9,510 payments were made on a monthly basis for nearly $5 million.

If I look quickly at the numbers for the year, I see that nearly $57 million was paid out from the Canada child benefit to families in Vaughan—Woodbridge. That is incredible. That is lifting families and their children out of poverty. That is helping families save for a rainy day and pay for their kids' winter boots. I understand it is a snow day back home in Vaughan—Woodbridge and that the buses were cancelled. If those funds paid for those kids to have an extra pair of boots or a new pair of boots, then I am proud of that.

The CCB is particularly helpful for families led by single parents. These families are most often led by single mothers, who tend to have lower total incomes. In fact, close to 95% of CCB amounts paid to single parents with incomes below $30,450 are paid to single mothers.

The government is committed to ensuring that Canada's tax system is fair, effective and competitive. I am certain that all hon. members know how important small businesses are to Canada's economy. They account for 70% of all private sector jobs and are vital drivers of economic growth in communities all across the country.

In looking at Bill S-6 and this tax convention with Madagascar, we see that this is another tax treaty that is made for the benefit of businesses on both sides of the Atlantic. We need to know that we as a country are eliminating barriers to investment and eliminating barriers to trade, and we have done that with the implementation of CETA and the implementation of the CPTPP and, mostly recently, the newly signed USMCA accord with the United States and Mexico, our two largest trading partners.

This is about creating good middle-class jobs, growing the economy, and growing the economy in an inclusive manner that benefits all Canadians, all middle-class Canadians and all those working very hard to join the middle class.

When small businesses succeed, Canada succeeds. That is why the government reduced the small business tax rate to 10% in January 2018, with a further reduction to 9% coming on January 1, 2019. These low tax rates will enable small businesses to create good, well-paying jobs in communities across Canada.

We know that the best poverty reduction plan is a job. It is giving Canadians skills training and lifelong learning. Hard-working Canadians and entrepreneurs, such as the 13,000 small business owners in the city of Vaughan and in my riding of Vaughan—Woodbridge, have created approximately 900,000 jobs in Canada since we were first elected. The unemployment rate hit around 5.4%—I think it is at 5.6%—because people are being drawn into the labour market. The unemployment rate is at a 40-year low, something that we should be proud of.

We know there is more work to do, but the fact is that there are over 500,000 job openings in Canada currently. The fact is that people from all over the world want to come and work and invest in our country. There is a reason for that: We have the best entrepreneurs, we have one of the best educational systems in the world, and we are a great place to invest. We have access, through three major trade deals, to all our major trading partners. We have free trade access to over 1.6 billion people, and businesses across the world know this.

These low tax rates will enable small businesses to create good, well-paying jobs in communities across Canada. When we say we expect these results from small business tax cuts, it is because we have a track record of success, giving us confidence in the direction we are headed.

Many positive signs tell us our plan is working. Since 2016, hard-working Canadians have created—as I said, to re-emphasize—hundreds of thousands of jobs, pushing the unemployment rate to a 40-year low and giving Canada one of the strongest records of economic growth in the G7.

Canadian workers are experiencing the strongest wage growth in a decade. We have seen some of the numbers that came out yesterday from the Canadian income survey, showing that after two years of stagnation, wages are on the rise and incomes are on the rise. That is more money in the pockets of Canadians, whether they are low-income, middle-class or upper-class. That is a good-news story. It is more income to invest, more income for Canadians and their families to save.

Most importantly, I would argue, as we compare our finances of governments around the world, that we have had the flexibility in Canada to invest in Canadians. We invest not only in skills training and the Canada child benefit but also in infrastructure through a $180-billion, 12-year infrastructure plan. We sat down at the table with our municipal, regional and provincial partners and worked on both the urban side and rural Canada, where we invested funds in both broadband and public transit. That is due to the inherent flexibility in our fiscal strength in Canada, where we can make these investments and plan for the long term.

Canada's net debt-to-GDP ratio is the lowest among all G7 countries, and we intend to maintain it and bring it down over the medium and long term. However, we understand, as Canadians do, that more needs to be done to encourage long-term economic growth. As I said earlier, one of the things we need to do is ensure that everyone pays his or her fair share of taxes. It is unacceptable that some corporations, both foreign-owned and Canadian, take advantage of Canada's tax rules to avoid tax. It is unacceptable that some wealthy people use offshore jurisdictions to hide income and evade tax.

I am happy to re-emphasize that we as a government, since taking office, have invested nearly $1 billion in CRA to provide it with resources, after a number of years when the prior government cut funding to agencies like CRA and did not allow them to have the tools to do their jobs effectively. We have reversed that. Canadians understand and appreciate that, because our services are delivered and funded through taxpayers, and, as a government, we respect them. We have lowered taxes for nine million Canadians, but we have also asked the wealthiest 1% to pay a little more, and those who attempt to avoid paying their fair share need to be held accountable.

We have addressed base erosion and profit shifting, which was recently debated in the House and which we had the pleasure of speaking to, and we have worked with our multilateral partners to look at ways to deal with transfer pricing for corporations, strengthening the exchange of information with our multilateral partners and providing the tools to CRA to do its job effectively. We need to ensure that corporations and wealthy individuals continue to pay their fair share of taxes and that our tax laws are being enforced judiciously, diligently and effectively.

In order to stop this profit shifting from happening, the Canada Revenue Agency needs information from foreign jurisdictions. That is why the tax convention in this bill puts in place measures to make possible the exchange of tax information from one country to the other. Bill S-6 would help Canadian tax authorities prevent international tax evasion while gathering the information they need to enforce our tax laws.

Canada's network of 93 income tax treaties currently in force is one of the largest in the world. However, we must keep updating and expanding this network in order to encourage international trade and make it easier for other countries to invest in Canada. In this way, getting our tax treaties in order will help the Canadian economy and Canadian businesses compete globally and enable them to hire workers, invest, grow our economy and improve the future of middle-class Canadians, such as those living in my riding of Vaughan—Woodbridge. Bill S-6 gives Canadians more certainty about the tax implications involved in doing business with, working in or investing in Madagascar.

This bill would make our tax system more efficient, while also ensuring tax fairness for Canadians who already pay their fair share. It would encourage more foreign investment in Canada, remove barriers to international trade and help grow and strengthen the middle class across the country. I encourage all members to support this bill.

As I conclude my remarks on Bill S-6, an act to implement the convention between Canada and the Republic of Madagascar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, I see this bill much like Bill C-82 on base erosion and profit shifting and much like the work we have done in the finance committee on a study with regard to tax avoidance and tax evasion, which was done very judiciously by the finance committee.

It is great to see committees doing the work that they are tasked to do independently. They work judiciously, make recommendations and produce reports, which are then looked at both externally and internally by ministers.

On this issue of a tax convention and its implementation, it is obviously very important for Canada as a country to work with all of its international partners, no matter how big or small, no matter how near or far, to ensure that we have the proper information exchanged between the two entities so that on a technical basis we ensure that we eliminate double taxation between the two countries for individuals investing both ways, reduce the risk of burdensome taxation and ensure that taxpayers are not subject to discriminatory taxation.

In closing, I will say that by strengthening our ties with Madagascar, our government is seeking out the kind of investments and trade opportunities that are vital to grow the economy.

I have spoken about the treaties we have put in place on the trade front, such as CETA, CPTPP and USMCA. I have also spoken of our plan to grow the economy by lowering taxes for middle-class Canadians and asking the 1% to pay a little more, and the results are bearing fruit. The numbers that were produced yesterday by Statistics Canada show that over 850,000 Canadians have been lifted out of poverty in the last two and a half years. These are real people working hard every day to provide for a better future for themselves and their families. We as a government will continue to invest in them, believe in them, work with them and work with all of our partners.

Canada–Madagascar Tax Convention Implementation Act, 2018Government Orders

February 21st, 2019 / 11:50 a.m.
See context

Bloc

Gabriel Ste-Marie Bloc Joliette, QC

Mr. Speaker, under Bill C-82, future tax agreements will be based on OECD standards, which allow for comprehensive tax information exchange.

We will continue to support that bill as well as Bill S-6, the Canada-Madagascar convention. We believe that the convention honours the spirit and the standards set out by the OECD even though the wording itself is not exactly the same as what was signed in Paris. Again, that is based on my understanding of the file.

Madagascar is not a tax haven at the moment, so, in my opinion, the wording about the information exchange agreement is fine. Obviously, it would be better if this were standardized across all our agreements, which is the goal of Bill C-82. The real problem lies with the tax information exchange agreements with tax havens, which make effective tax information exchange complicated or well-nigh impossible.

In such cases, the Canada Revenue Agency has to request specific information about a known taxpayer. We do not have enough information to monitor data about information exchange. If everything were available, auditors could identify situations in which tax fraud or tax evasion likely took place. That is what needs to change. Tax information exchange agreements with tax havens are the problem.

I would remind members that when these agreements were entered into with tax havens, the Income Tax Act was changed. It was not done openly, but hidden in the information on medical expenses, among the thousands of pages of the Income Tax Act. It stated that when Canada enters into an agreement with a tax haven, the portion of income that the Canadian corporation declares was generated in the foreign country will no longer be taxable here. The income will only be taxed in the tax haven, where the tax rate is zero or close to that. That is what we are speaking out against and it must change.

Canada is a lame duck in the fight against tax avoidance; it is letting the big banks and multinationals shift their profits to tax havens under these agreements. At the time, there were 22 agreements. This is still going on. Things have to change.

I introduced a motion in the House to do just that. Every Liberal, except for one, and every Conservative member voted against the motion. Do the parties that aspire to govern represent the Canadians who want to eliminate the use of tax havens, or do they serve the big corporations and major banks that are the main beneficiaries of these immoral schemes?

I think that in asking the question, we have our answer. This must change.

Canada–Madagascar Tax Convention Implementation Act, 2018Government Orders

February 21st, 2019 / 11:50 a.m.
See context

NDP

Pierre-Luc Dusseault NDP Sherbrooke, QC

Mr. Speaker, I thank my colleague for his speech and his expertise on the matter. I know that he also analyzed Bill C-82. I am sure that he fully understands the fact that this bill aims to renew and improve our tax treaties. Our partners must also accept the improvement of a treaty; it goes both ways.

Today, we are studying Bill S-6, a tax treaty with Madagascar. However, this treaty was modelled on the old system. The tax treaty was signed on November 24, 2016, and the multilateral treaty, which is the subject of Bill C-82, was signed on the same day in Paris. Therefore, while a treaty was being signed in Antananarivo, Madagascar, and another in Paris, two different things were being signed.

Can my colleague tell us about the difference between the new and improved OECD treaties, which were adopted in Paris, and the one signed in Madagascar, which is based on a version that the government believes taxpayers can abuse?

February 21st, 2019 / 11:25 a.m.
See context

Liberal

The Chair Liberal Wayne Easter

That's a question you can raise when we get to your time, Mr. Masse.

The floor is back to you, Mr. Poilievre. Please stay on Bill C-82 and the estimates.

I know you're trying to say that I'm trying to shut this down. No, I'm not. There is a place for those questions to be raised. There are appropriate committees, if it goes before them, in terms of that issue. I believe the justice committee is dealing with that issue. There's also the House of Commons, where you can raise anything that you desire to raise. However, as stated on the agenda, this hearing today is on Bill C-82 and the estimates, and the estimates are quite broad in terms of the finances of the nation. We have a deputy minister here, as well, with Mr. Lightbound and other officials.

So, the floor is yours, and if we can stick to that, it will be great.

February 21st, 2019 / 11:25 a.m.
See context

NDP

Brian Masse NDP Windsor West, ON

Mr. Chair, the only thing I want clarification—and I'm a guest at this committee—would be on Bill C-82 and whether international corporations are subject to that. If that's the case, then I believe it is in order.

That's the only thing that I would suggest that we look at with regard to this process of a difference of opinion on it: whether the bill actually applies to international corporations doing work abroad.

February 21st, 2019 / 11:25 a.m.
See context

Liberal

Francesco Sorbara Liberal Vaughan—Woodbridge, ON

—such behaviour.

We're here to talk about Bill C-82 and this reference. The material that Mr. Poilievre has brought up has nothing to do with what we are here to talk about. I'd like to have a ruling on whether we need to stick to the material or whether we wander off on some fishing expedition.

February 21st, 2019 / 11:25 a.m.
See context

Liberal

Francesco Sorbara Liberal Vaughan—Woodbridge, ON

Thank you, Mr. Chair.

Mr. Chair, we're here this morning to discuss Bill C-82 and also, pursuant to Standing Order 81, to look at interim estimates 2019-20, votes 1 and 5 under Department of Finance, vote 1 under Financial Transactions and Reports Analysis Centre of Canada and vote 1 under Office of the Superintendent of Financial Institutions, referred to the committee on Monday, January 28, 2019.

I've been on this committee since I was elected, and I have the privilege to serve the residents of Vaughan—Woodbridge. We're here to do the work of our residents. We are here today to analyze and to ask questions of the parliamentary secretary, Mr. Lightbound, and the officials.

Thank you for being here again. I'm sorry you're having to witness—