Bill C-82 (Historical)

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 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.

Multilateral Instrument in Respect of Tax Conventions Act

[Garnett Genuis, Conservative, Sherwood Park—Fort Saskatchewan, AB]

Mr. Speaker, before I get to my prepared remarks, I just cannot let this moment with my colleague from Timmins—James Bay pass. It really is incredible to see the other parties, the Liberals and New Democrats, stand up as if they are champions of the underdog, yet when they have an opportunity to pass real, substantive measures that would hold government accountable, that would require government to treat people consistently with fairness and respect, every time they have a chance to put their votes where their mouths are, they are found wanting. Given the passion of that member today, I could not believe that he would have voted against the motion I referred to, so I had to look it up and confirm that it was only Conservatives who voted in favour of imposing a duty of care on the Canada Revenue Agency.

If people at home believe that the Canada Revenue Agency in its interactions with taxpayers should have a duty of care, there is only one party in the House that has stood up for that. It was the Conservative Party. There is only one party that said that single moms who are being attacked by the CRA and small businesses being pursued by the CRA for money they do not owe deserve to have a duty of care imposed on the CRA for their protection. This was a great initiative put forward by my colleague from Calgary Rocky Ridge. He said that a study should be done at committee to ensure there was an enforceable duty of care between the Canada Revenue Agency and individual taxpayers, which seems pretty reasonable, and that necessary steps be taken to make the provisions of the Taxpayer Bill of Rights legally enforceable, such as by amending the Canada Revenue Agency Act to establish a duty of care.

It was a motion, not legislation, so it would have set the terms for a study to begin this process. Therefore, crucially, my colleagues across the way had no excuse to vote against it on a technicality. It was to set out direction for a study by committee to move forward with bringing about this duty of care. However, they voted against it. They had a responsibility to put their votes where their mouths were, and they did not.

The holier-than-thou member for Timmins—James Bay says that he is standing up for his constituents in the House while voting against their interests. When I asked him about his vote on Motion No. 43, he had to talk about something completely unrelated, saying that the Conservative Party does not stand up for this, that, and the other thing. That is exactly the response we would expect from someone who realizes his votes in the past do not match the comments he has made.

Mr. Speaker, I am very pleased to rise in the House to speak to Bill C-82. This is a good opportunity to clarify international tax rules, more specifically those concerning base erosion and profit shifting.

It is no secret that many multinational corporations use a multitude of strategies to avoid paying higher taxes. They shift their profits to a territory with a lower tax rate in order to avoid paying taxes. This strategy of shifting profits from one territory to another, as well as other tax evasion strategies, costs the Government of Canada billions of dollars.

This multilateral convention seeks to mitigate this problem by clarifying in which territories profits must be declared and taxed. The hope is that with these new rules, multinational corporations will no longer be able to shift their profits from Canada to another territory to lower their tax burden.

It is important to note that this convention will not affect the small businesses that this Liberal government has often attacked. This bill will have more of an impact on multinational corporations. The Liberals may have realized that they cannot keep attacking small businesses if they want to win the next election, but I am not holding my breath.

In the past, the Liberals called small business owners tax cheats. They said they were wealthy people who set up businesses to avoid paying their fair share of taxes. The Liberals created new regulations that increased the tax burden on small businesses, and they justified these measures by saying that they wanted the system to be fairer.

I do not understand how making small business owners pay more taxes will make the system fairer. Perhaps the Liberals can justify these attacks by saying that small business owners are tax cheats. I believe that the Liberals are not going to change their minds about small businesses.

The multilateral convention will also eliminate double taxation. It will clarify which territory has the right to impose a tax on which profit. The Conservative Party has always been in favour of simplifying the tax system. We believe that this convention is a good first step. Of course, we have a lot more work to do to simplify our tax system, but if we can start with the international tax regime, that is a good first step.

Since attaining the objectives of the convention requires the exchange of information with the competent authorities of other territories, this convention also includes a provision on that.

There will be strict rules on how this information can be used and when it must be protected. This information is crucial to the fair enforcement of Canada's tax laws and the enforcement of this convention and the tax laws of the signatory countries.

These reforms are also important because simplifying the international tax system will strengthen relations between Canada and the other signatories. Clearer international tax rules and laws will facilitate trade between countries. When countries trade, they prosper and are more likely to maintain peace.

I am pleased to see that for now, the Liberals have decided to stop going after small business owners and ordinary Canadians to pay for the Liberals' reckless spending. I am pleased to see that they have decided to go after national corporations' taxes instead. Unfortunately, this is not usually the case. Usually, the Liberals go after small business owners, the middle class and those who are working hard to join it.

First, they increased taxes on small businesses, claiming their owners were wealthy people who were trying to avoid paying their fair share. Now, they want to impose a carbon tax, and it is not because they want to protect the environment. This tax will do nothing for the environment. It is because they have to find some way to pay for their reckless spending. The Liberals keep going after average Canadians so that they can pay for their irresponsible deficit. The Liberals do not seem to understand that they should not be going after Canadian workers and small businesses that are already paying their fair share.

Having explained some of the particulars of the bill, in the remaining time I have before question period I want to make a few other observations about how the philosophy of this bill relates to other actions of the government.

We are discussing the issue of tax avoidance. One observation that should come out of this is that those who have greater wealth and a greater capacity to hire lawyers to study the rules often have a greater capacity to engage in activities that involve tax avoidance. When we have a more complicated tax system, it generally advantages those who are well off, because they have the capacity to develop mechanisms for avoiding those taxes. However, in this party, we advocate simple, clear, low taxes that ensure that the benefits of low taxes are accrued equally, and in particular that we deliver tax relief to those who need tax relief the most. That has always been the record of Conservatives.

When we were in government, we lowered the lowest marginal rate of tax. We lowered the GST. We raised the base personal exemption. We increased the amount of money that a Canadian could earn before they pay any income tax. All of our tax measures were targeted on the income tax side and were targeted at those who needed the relief the most. We are very proud of that record. However, what has the current government done? It raised taxes in the name of helping the middle class. In reality, it never closed the tax loopholes that are advantageous for themselves and their friends.

When it comes to the capacity for tax avoidance, let us talk about the carbon tax. A single mother who is barely getting by cannot afford the home retrofits that might be required if she were to make a substantial change in the carbon tax she was paying. How about giving people the capacity to make decisions that are good for themselves and the environment rather than punishing people who actually do not have the capacity to make those kinds of investments?

There are some Canadians who have the wealth and resources to take advantage of things like the programs that the previous Ontario Liberal government put in place that really directed resources towards the wealthy, towards those who could take advantage of those opportunities. When we think that a climate policy is hitting people with a stick instead of giving them a carrot, if those are people who cannot actually change their situation because they do not have the capacity to participate in tax avoidance types of activities by changing aspects of their lifestyle, then they are stuck paying higher taxes.

We see consistently with the government, through aggressive tax policies, increases in taxes that perversely target those who can accept those increases the least. Meanwhile, when Conservatives were in government, we cut taxes and we have always targeted tax relief to those who need the tax relief the most.

[Charlie Angus, NDP, Timmins—James Bay, ON]

Mr. Speaker, as the spokesperson for the people of Timmins—James Bay, I am very proud to be here today to take part in the debate on Bill C-82, which seeks to implement measures to prevent base erosion.

When I look at this bill, I have one simple question: where is this government's plan to close tax loopholes? Workers across Canada pay their fair share of taxes, but wealthy people, corporations and Liberal cronies can use tax havens. It is unacceptable. Tax havens have undermined our country's ability to develop a fair and equitable economy.

I want to talk about this conversation we have been having this morning where the Liberals talk about tax fairness and closing loopholes. I do not often agree with the Liberal Party, but I will say that the Liberals have been very committed to closing tax loopholes. However, they are not committed to closing them on the friends of the Liberal Party. They have been using the massive resources of the CRA to go after single moms, young families and small businesses.

We see one of the great and I think really disturbing political frauds in the last few years. The government says again and again it is committed to getting money to young families through the Canada child tax benefit, but what it does not say is that it is clawing that money back through a whole series of measures, which are actually cruel in their implementation, and targeting people who have no capacity to defend themselves.

I could give a few comparisons to show how unfair this system is in terms of how the Liberals look after the friends of the Liberal Party.

Let us talk about the need to deal with the tax avoidance system. The problem with the super rich not paying their part has a massive impact on the erosion of our economy, and our ability to make investments and to build an economy that is fair and just across this country. We are learning now that tax avoidance is upwards of $3 billion a year, but there may be $70 billion to $240 billion being held offshore and out of access to the Canada Revenue Agency.

What is the Canada Revenue Agency's response to such massive tax avoidance? Well, we saw how the government made a deal with KPMG after it was found out that KPMG was involved in establishing scams for those who had $5 million to blow. Now, not many people out there in television land probably have $5 million to spare, but if one is friends with the Liberal Party it is likely one may and could be set up in offshore tax havens, which is cheating.

When a small business in my region gets caught out not paying its taxes, the government brings the full weight of the law down on it. There is no mercy. I have never seen mercy from the CRA, ever. If one is not paying one's taxes, that is the way it has to be. However, why would the government make an agreement, why would the Prime Minister make an agreement, with KPMG, people who are tied to the Liberal Party and people who are tied to getting federal contacts, to give them an amnesty for avoiding taxes? That does not happen if one is a single mom with an overpayment on EI.

Let us talk about Stephen Bronfman, who is a very close friend of the Prime Minister. He is the Liberals' top fundraiser. In fact, he is so good at raising funds, he helped raise $250,000 in two hours for the Liberal Party. I mean, they just travel in different circles than the rest of us Canadians do. When Stephen Bronfman gets named in the Panama papers, one would think that would be a serious question for the legitimacy of the friends of the Prime Minister and the need to deal with tax loopholes and unfairness. However, the Prime Minister came out and said immediately that there was no investigation needed. He was a friend of his. Know what? No investigation happened.

My young daughter, who just starting working and makes minimum wage, is being audited for the second time. She was audited last year and is being audited a second time. I told her to get used to it. A young student trying to pay her rent might get audited by the CRA all manner of times, but I would never call the CRA to say she's my daughter and does not need to be audited. That would never happen. However, the Prime Minister went public, said Stephen Bronfman is a good guy and does not need to be audited, when he was named in the Paradise papers, and it never happened.

Who else was named in the Paradise papers? There was Leo Kolber. This was about the trust that was set up for the Kolber family. For those who do not know and are not part of the Laurentian class, Leo is a Liberal senator and a very well-placed Liberal bagman. He was named.

Paul Martin was named, but I guess that should not be surprising. Paul Martin made his name by keeping his ships offshore so he did not have to pay taxes. Paul Martin was named in the Paradise papers. Jean Chrétien was named in the Paradise papers.

Then, of course, there is the finance minister. Morneau Shepell had its Bahamas subsidiary. What would anyone be going to the Bahamas for, one of the notorious tax havens? Of course, there was lots of tax work to do there and Morneau Shepell had its subsidiary in the Bahamas. When the government says it is going to take special measures to deal with the Bahamas, set up with the finance minister, does anybody in any place in this country think it is going to be looking after the little guy? I do not think so.

It keeps going on and on. There is the Minister of Infrastructure. There was a report in Le Journal de Montréal about the Minister of Infrastructure and the transfer of payments to shareholders of a company in, wait for it, the Turks and Caicos. Folks back home who work at the mill, at the mine or at Tim Hortons might wonder why someone would have shares in the Turks and Caicos and wonder where it is. It is well known for offshore finance operations. Maybe we will be talking, if we have enough time, about the privatized infrastructure bank that was set up. I bet a lot of people from the Turks and Caicos will be very interested.

I am not being mean to just the Liberals. We can talk about the famous Nicole Eaton, a senator. When a bunch of documents were released from the notorious Bahamas, it turned out that she was a director of a corporation called Mount Bodun Limited and said she had no idea how she was named as a director of this corporation. That stuff happens to me all the time. I find out I am a director of a corporation in the Bahamas. Shrug, shrug, how did that happen? I guess it is the world that they are travelling in.

Let us go back to the illustrious upper chamber. Of course, we could not have this discussion about offshore tax havens without talking about Liberal Senator Pana Merchant. It was said that her husband “moved nearly $2 million to secretive financial havens while he was locked in battle with the Canada Revenue Agency”, and she gets paid until she is 75 by Canadian taxpayers to represent our interests.

What happens is really interesting. When rich people like these move assets around outside the hands of the CRA, what happens? Nothing happens. That speaks to the fundamental problem we are seeing, the unfairness, because ordinary Canadians pay their fair share of taxes. They work really hard, they are diligent and they pay their fair share. Therefore, when we see the super rich and the friends of Laurentian and Liberal class not paying their share, we have a problem, unless one thinks that the CRA is the most relaxed, laid-back organization and does not like making life difficult for anybody over taxes.

Let me give an example of what happens for people who are not super rich. Let us talk about what happens for the working poor and how they get treated. Let us also talk about the Canada child tax benefit, because again the great fraud that is being perpetrated by the government day in, day out is this great miracle of the child tax benefit that everyone gets and brings everyone out of poverty. What Liberals do not say after they make those announcements is that they use the resources of the Canada Revenue Agency to claw it back, and the vast majority of cases coming through my office right now—and I have talked to many members of Parliament—are single moms being denied the child tax benefit because of the loopholes that they are being forced to jump through. What are some of those loopholes?

A young father came into my office. His wife left town and left him with the kids. He did not know where she went. He had to quit his job to look after the little children. He was cut off from his child tax benefit because he could not prove where she was. At Christmastime the neighbours were putting together food hampers for the family because the family had nothing.

It is not just single moms. A young couple was told after getting the funds to go back and prove who they were, prove that they were married and where the children were, even though they had always had the children. Single moms are being told they are being cut off because they cannot prove they have their children. They say the children go to the local school, but the government will not accept report cards as proof anymore. It is not fair to make a single mom jump through those kinds of hoops when we would not make Stephen Bronfman do it.

I know a wonderful young Cree mother who has the most beautiful little girl and in six years that mother has never received any child tax benefit. Why? The government does not believe she actually lives in the country. She is not living in the Turks and Caicos. She is living in social housing. She is working and raising her child but she is not getting a single dime from the government. Officials tell her she has to go to the doctor or the dentist, but that is not good enough. Then she has to go to the landlord. They even told her to get the mailman to sign something confirming where she lives. She has paid her taxes every single year.

There are mothers who do not have proper housing, so they are couch surfing. When they are couch surfing, CRA says their address indicates that they are staying with their folks and it is cutting them off. CRA will make single moms jump through all kinds of hoops, but would not make anybody whose name is in the Panama papers go through that.

One of the other things the CRA has come up with is that for people to get the child tax benefit, they have to show proof of insurance on their residence and on their children. The people I represent such as single moms in poverty do not have insurance. I guess if someone is the finance minister and cannot remember he owns a chateau in the south of France, he probably thinks it is great: “We should just find out what people's insurance is.” What kind of idiotic loophole is it, telling a poor mother to prove she has insurance for her kids and maybe the CRA will give her the benefit? If she had insurance, she probably would not be so desperate to get the child tax benefit.

The government talks about the middle class and those wanting to join it. If it were a Liberal drinking game and the Prime Minister gave a speech, he would be bombed after the first five minutes if he had to respond every time he said the middle class and those wanting to join it. I do not want to be mean to the Prime Minister, but I think he and I grew up in different middle classes.

When I was young and starting out, my wife and I started a small business. We barely made ends meet, but we paid our taxes. We paid our employees. We worked really hard. I was really surprised when the Prime Minister talked about small business in the 2015 election. He worried they were being used as millionaire tax dodges.

For two terms I was on the Tri-Town and District Chamber of Commerce in northern Ontario. I did not know anyone sitting around that table who were there because they were establishing millionaire tax dodges. Small businesses are the backbone of the economy and people work really hard. It seemed to me such a disconnect that the Prime Minister said we would have to watch small businesses because they are millionaire tax dodges, but then of course, he would know because he set up three numbered companies to handle his income, his investments and also the money he was getting as a member of Parliament to do public speaking so it would lower his tax rate. From his perspective, everyone else must be doing it, but other people are not doing it.

What do we need to do? We need to start addressing tax fairness in a coherent manner. We need to review the overall tax system. The last time it was reviewed was in the 1960s. We are in a very different world now in terms of tax avoidance, in terms of corporations not paying their share. More and more the cost of social services is being downloaded onto municipalities. Single households and people in the middle class pay a very good chunk of taxes.

We need, number one, an overview of the tax system. We need a really clear sense of where tax avoidance is happening. I was really surprised to see that the government fought so hard against the Parliamentary Budget Officer over the simple question of identifying where the tax bleeding is happening. If we can see where the tax bleeding is happening, we can start to make changes.

Then we need a government that will spend more time going after the superbillionaires who are hiding their money in the Turks and Caicos than going after single moms. That should be a fundamental principle that all members in the House, regardless of their political ideology, agree with. Young people, single mothers and young families who are trying to get by should not have to bear the kinds of burdens CRA is putting on them, as though they were criminals for being entitled to this money.

We should be putting those resources into actually tracking and going after those who use tax havens. For those who use tax havens, like corporations, there has to be some kind of punishment. An example is KPMG. We have to start saying that if people are using international tax havens and are found guilty of not paying their fair share, they will be disallowed from getting federal contracts for a period of, say, five years. That would send a message that we are serious. Many companies in this country play by the rules and do everything that is asked of them and more to make sure they are compliant. The outliers that do not play by the rules should not be rewarded for shipping resources offshore to avoid their basic responsibility, which is to ensure we have a tax system that works so that we can make the investments needed to grow a more fair economy, a more just economy, an economy in which people can live the kinds of lives they deserve to live in this country. A coherent tax policy is important for this.

As much as I am okay with the fact that we are going to sign a bunch of tax agreements with a bunch of countries, which is all right, I want to know when we are going to start getting serious about going after these tax havens and the Canadians who use them.

[Tom Kmiec, Conservative, Calgary Shepard, AB]

Mr. Speaker, I am not a tax lawyer, and this is one of those very technical questions I am not able to answer. Under the permanent establishment definitions that are part of this international initiative that Bill C-82 would implement, there might be an opportunity to ensure those types of definitions are included. Outside of that, it would have to be the hybrid mismatch arrangements and the anti-treaty abuse provisions, where I guess one would find these intellectual property rights and trademark provisions in order to ensure that type of behaviour is clamped down on.

[Erin Weir, Independent, Regina—Lewvan, SK]

Mr. Speaker, I would like to thank the member for Calgary Shepard for bringing up the challenge posed by intellectual property, where it is very difficult for tax authorities to determine where it is located and how much it is worth. Now, there is a potential solution to that, which is called “formulary apportionment”, essentially allocating a company's profits based on the actual location of its sales and payrolls. We are familiar with the system in Canada because the Canada Revenue Agency does not allow companies to move their profits around between provinces based on transfer pricing. It actually requires them to allocate their Canadian profits based on where they actually employ people and sell their goods and services.

Since we are talking about an attempt at international co-operation through Bill C-82, does the member for Calgary Shepard see prospects to apply formulary apportionment at the international level?

[Tom Kmiec, Conservative, Calgary Shepard, AB]

Mr. Speaker, there is a Yiddish proverb that goes, “A quarrel is like an itch; the more you scratch, the more it itches.” I am glad the member satisfied the itch I had, by bringing it back to just talking about more of the generalities rather than specifics of this tax treaty of tax treaties bill.

Yes, the government has done some things. Again, Bill C-82 is the government's attempt to go after multinational corporations that are taking advantage of base erosion and profit shifting, doing things bordering on aggressive tax planning.

What I am pointing out, though, is that in the CRA's drive to try to collect more taxes from overseas corporations, that same zest and zealotry is being applied to small business owners in Canada, to single moms simply trying to apply for child benefits, and to type 1 diabetics, whose only crime really is they wanted to apply for a disability tax credit. I went through this over the summer, when I was trying to figure out how to apply for the disability tax credit for my youngest daughter. It was a process where I was thankful I had spent a year drafting a private member's bill, because I am not sure I would have been able to do it all by myself. The complexity of complying with CRA rules and regulations at times makes it impossible for average Canadians to be able to file their taxes.

[Tom Kmiec, Conservative, Calgary Shepard, AB]

Mr. Speaker, I am glad to be back this Monday to talk about what I think is a tax treaty for tax treaties. I can think of no drier subject to debate in the House other than maybe ways and means motions.

Bill C-82 looks at base erosion and profit shifting. It is a problem that tax regimes and tax administrators across different countries are increasingly starting to grasp as a result of the digital age now upon us and the ability of companies to create sub-companies and larger holding companies to shift around money quite easily, as well as IT, or intellectual property. They are able to shift the work of employees in a digital sense, not in a physical sense, to other countries to take advantage of lower taxes and tax loopholes and tax avoidance schemes that currently are legal in some ways, but in other ways go against the spirit of tax treaties that legislatures have introduced across different countries.

The Tax Justice Network has done some estimates and provided an aggregate of different statistics from the OECD, World Bank and IMF of how much money we are talking about in base erosion and profit shifting. It could be an excess of $200 billion that developing countries are losing out on from that money being shifted around. This is revenue that could be taxed and possibly provide social services that we all live off of. We need police forces and EMS. Also, this place does not run for free. We have to pay the clerks. We have to pay all of those who provide administration for this building. Some of the lowest estimates are as low as $100 billion while some of the higher one go up to about $300 billion. Large multinational corporations are typically best able to take advantage of different tax treaties and tax treatments for the type of work they do. This is happening mostly because the digital age is upon us and the ease with which companies can hire experts in this field.

Let us be honest. I am not a tax lawyer. Neither are the vast majority of the members in the House. I am humble enough to say this. Whenever I see a tax bill before the House, it takes me an extra long time to go through it. When I have to file my taxes every single year, it takes me the better part of an afternoon to do it. Dealing with tax treaties and their tax implications for multinational corporations and how these could be used is not my area of specialty. Those companies know that. Multinational companies are able to hire high-paid accountants, high-paid lawyers and high-paid lobbyists to ensure that they get the best possible tax treatment for their businesses. In some cases it may be justified to avoid a situation of being double taxed.

In Bill C-82, a lot of the provisions in this tax treaty for tax treaties will get rid of the double taxation of some companies. However, many simply abuse the rules. There are 78 jurisdictions that will be covered by this and 1,200-plus matching treaties that will be looked at. Countries are joining this process every day.

This was not started by the current Liberal government, let us be clear. It began under the previous Conservative government as a result of multinational bodies starting to look at this matter. I have heard several members on the government benches say this is part of the their initiative to improve tax collection somehow. They are taking credit for something that others started. The government repeatedly takes credit for things that others have done, either things that civic society has done or charities are doing on their own, or that a previous government has done or a provincial government is doing. The government takes these as its own, claiming victory that somehow these meet the campaign promises that the Liberals were elected upon.

I have an example that I found in a package that the OECD made available on its website. I want to read it into the record because it is an example of base erosion and profit shifting.

In the example set out in the video, company A, which resides in the Cayman Islands, wants to provide a licence for the use of intellectual property to company C in South Africa. South Africa, however, has not concluded a tax treaty with the Cayman Islands and would thus be entitled to apply its domestic withholding tax rate on outbound royalties. I hope that everyone is still with me on this. However, a European country has concluded a tax treaty with South Africa that reduced its withholding tax rates on royalties. Also, this country does not itself levy a source tax on royalties. Therefore, company A establishes a letterbox company in this European country and diverts the royalty payments through the letterbox company to reduce the tax withheld by South Africa. In this example, the principal purpose of establishing this arrangement, including the letterbox company, was to obtain the lower withholding tax rate available under the tax treaty between South Africa and the European country.

If everyone is still with me, that is what we call “base erosion profit shifting” in its simplest sense. Large international companies like Starbucks do this. Every time we go to Starbucks to get a triple spiced pumpkin latte, or whatever, that company engages in this type of behaviour. I am sure I am going to get a phone call from one of its lobbyists. Specifically, it is a popular thing to do with intellectual property and trademarks, particularly in the arts and cultural industries. At a certain size we are talking about large sums of money. In these cases, the trademarks and intellectual property have a very high value. A company's reputation and branding are how it differentiates itself from its competitors.

This matter is international. We also have it happening in a certain way domestically. We have a government that has been pursuing single moms, small business owners, and many residents in my riding who have been trying to make ends meet. The government wants to force them to provide documentation proving they are not engaging in tax avoidance or welfare fraud of some sort.

Other members have said that the Alberta registered corporation that the Minister of Finance uses is really a form of tax avoidance. It is not illegal in any way in Canada to go outside a jurisdiction where the work is being done in order to register in a lower tax jurisdiction, Alberta in this case, to avoid paying more taxes.

It is done domestically, which is why the Standing Committee on Finance has been doing a statutory review of the proceeds of crime and terrorist financing act. The reason I bring it up is that in the process of this study, the members of the committee would have had an amazing opportunity to learn from FINTRAC and other agencies of the government that are dedicated to tracking down illicit funds and suspicious transactions and activities.

What we do domestically has implications internationally. We know that business owners are engaging in aggressive tax planning, making use of tax firms and tax consultants, such as KPMG, PWC and all of the large firms out there. KPMG is notably the one that has made the news most often with its relationship with the Canada Revenue Agency. These companies are aggressively planning businesses' taxes to help them avoid paying their “fair share”. It is not a term I like to use, but it is one that has been used quite often in the House.

I wish we spent more time talking about how to get companies and Canadians to create more wealth. We spend an awful lot of time in the House trying to figure out ways to tax people and corporations in order to try to squeeze and get more water out of that stone in some way, but we do not really spend a whole lot of time talking about how to make sure that in the free market economy, where free people are working in their own best interests and figuring out how to make ends meet for their families, we can simplify and improve their lives. We are not doing that. We have been doing the opposite for the past three years. From this so-called middle-income tax cut, a Canadian who is earning $48,000 is saving $81.44 off their taxes. If we include carbon taxes, increased payroll taxes, depending on the provincial jurisdiction, where they are probably paying higher provincial taxes as well, costs are rising, including the costs of everyday essentials.

There are think tanks that say that the number one item on the average family's pay slip is taxes. They are paying more for taxes than for the essentials of life: rent, food, electricity or natural gas. For the first time ever, the average family is having to pay more in taxes than for anything else. We do not spend enough time talking about how to create more wealth and to broaden the base that has been a way of ensuring that more Canadians and corporations are at least paying a little bit into the system. When we pay into the system, it makes us part of it. There is a certain ownership in what the Government of Canada and what the Parliament of Canada do on our behalf. When we have to put a little money into it, we really do care what is being done with it.

The Liberals said in their campaign platform that a so-called tax hike on the top 1% would bring in $3 billion more. The Department of Finance then produced an estimate, saying it would bring in an extra $2 billion. The government actually lost money in its first year; $4.5 billion to $4.6 billion less money being brought in. Those are not my numbers. Those are Statistics Canada and CRA numbers, which say the government is bringing in less money than it did before.

The top 1% of income earners pay 20% of all taxes. The top 8% of income earners, including every member in the House, every cabinet minister, are paying half of all taxes right now. That is an incredible amount, just in the share of national revenue, that we are asking an increasingly smaller group of people to pay. It also speaks to the administration and the idea of taxing the rich, fleecing the rich, on a personal income side, which has been a total failure of the government.

Now we have Bill C-82, in which the Liberals want to go after multinational corporations and big business, and I am all for it. It is a fantastic idea. We have a tax treaty of tax treaties. It should be done right. I am glad we are at this point where we can talk about it.

However, where are we talking about the wealth creation to get small businesses and entrepreneurs to start creating more jobs, to want to invest? We had the aborted attempt by the Minister of Finance's department, and by him as well, to tax small businesses more because they were not paying their fair share. I heard loud and clear from general practitioners and small business owners in my riding who were just trying to make ends meet. They wondered how they could keep growing their small family businesses and eke out an existence to pay for the schooling for their kids and to continue living.

Calgary continues to have the highest unemployment rate in Canada. The reason for that is that the Government of Canada is in no way interested in ensuring that the energy industry of Alberta continues humming along. Most high-income earners come from Alberta. The Government of Canada has made changes to the tanker ban on the coast of British Columbia and the introduction of Bill C-69, which has passed through the House and is in another place. Every regulatory and legislative measure that the Government of Canada has been able to use to constrict and put the energy industry of Alberta into a pretzel, it has done it. The Liberals have succeeded in reducing our incomes. They have succeeded in undermining the ability of Albertans and Alberta families to make a living. They are not helping to create the wealth that they want to tax. We should be starting the conversation with how we can ensure people can create wealth for themselves and the Government of Canada can tax a reasonable amount from them to pay for common, public services that we all get to enjoy.

For multinational corporations, what we are talking about in this tax treaty is base erosion. They are using a digital economy to shift around so-called profits, and this is primarily used by big businesses. The ability of small businesses to do this is very limited because they need access to high-paid tax lawyers, lobbyists and accountants who know the details of these tax treaties, who can read the different tax treaties between different countries and take advantage of specific provisions in them.

After the paradise papers and the Panama papers, I think there is a general understanding among parliamentarians in both houses that something has to be done. It is not just in North America and in Canada that base erosion and profit-shifting for large multinationals is getting out of control. It is happening in European and developing countries as well. With the digital economy and the ability to cite their so-called work locations almost anywhere they wish, it has become profitable for companies to engage in this type of tax avoidance.

We also have to remember that they are trying to avoid taxes, sometimes punishing taxes, that limit their ability to continue working, to continue generating a profit for shareholders. If they are co-operatives, it limits their ability to provide a return to the members of the co-operatives. It goes back to the notion of whether we are creating an opportunity to create wealth. Instead, we usually talked about how we can tax more.

Another example is that during the whole cannabis decriminalization and legalization, the discussion primarily in the public was about how much taxes the Government of Canada would generate through the legalization provisions it had introduced. Oftentimes we did not talk about the potential for wealth creation through these businesses, through legalizing this one sector of the illegal economy, the black market that already exists.

The United States will not be a party to these international tax treaties that Canada and many other countries have, to this multinational effort on the base erosion of profit shifting, although it would be in its best interest to do so because it stands to gain quite a bit from it as well.

Canada's competitiveness is further eroding. We do not participate in measures such as this. The provisions in our federal corporate income taxes and the tax rates in comparison to those in the United States make us not competitive. In Canada, one of its champions for natural gas just cannot continue doing business in Canada at this pace. It costs it $100,000 in carbon taxes for every well drilled in British Columbia. That is a rig hand, an extra person on every rig who could be hired who did not need to be.

The Government of Canada crows about how great it is doing on the energy file, such as the LNG project that was approved. However, it does not talk about the $70 billion to $75 billion in projects that did not go ahead. It does not talk about the fact that this project, the LNG project, was approved in 2014. Businesses took until 2018 to decide to go ahead with it. They only went ahead when they got exempted from the carbon tax.

Large multinational corporations have been exempted from the domestic carbon tax that everyday Canadians will have to pay, every small business owner who owns a convenience store and every gentleman I meet who drives my Uber. Usually in Calgary it is a form of an oil and gas war. The drivers of my Ubers will pay higher carbon taxes, will pay a higher price on their gasoline, will pay a higher price on their natural gas to heat their homes. They will have to pay for that, but multinational corporations will not have to pay. That was the inducement, on top of other inducements, necessary to get them to invest in Canada.

I am all for Bill C-82, what I call the tax treaty of tax treaties, the driest subject we could possibly talk about. However, let us go back and talk about how we can get people to create more wealth. I do not mean the government-directed creation of wealth. I see this all the time in news releases, that the government created 100,000 jobs. It created no such thing. This place is not capable of creating jobs. People out there create jobs. They start businesses. They may start a family business. They go out and find a product or a service that somebody out there wants to buy. They fill a gap, a niche in the free market. That is popular capitalism. It is capitalism for the people. We do not talk about it enough in this place.

In this place what we often talk about is select industries that deserve a tax break or special treatment of some sort. I am glad we are going ahead and ensuring that base erosion and profit shifting stop happening as easily as they have been.

Let us go back to talking about how we can get junior oil and gas companies in Alberta to start drilling again, to start hiring again. Probably 10% to 15% of the people who live in my riding are either unemployed or underemployed. They are maybe working a day or two a week. This is years after the commodity prices, the so-called grand WTI went down. We do not even get that in Alberta. Last week, we were told that WCS, a standard Canadian mix of bitumen and dilbit, was selling at zero. Companies were paying others to take it for 8¢ to 18¢. They had to pay someone to take it because there was so much supply.

We rarely talk about all of these problems. We posture, which is pretty standard from that side of the benches. I do not hear us talk about wealth creation. How can we get people to create their own wealth? Then, at that time, the Government of Canada can come by and ask for a reasonable share of that amount.

However, for multinational corporations, I hope this treaty will be the starting point for reducing their ability to rob from the public purse, which should be justly paid to the Government of Canada for the provision of services that we all enjoy.

[Darrell Samson, Liberal, Sackville—Preston—Chezzetcook, NS]

Mr. Speaker, I do not know if my colleague should share the bad news with the company or if he wants the CRA to do so, but if it is not paying its taxes, Bill C-82 would force it to pay them. The member may deliver the bad news if he wants to, or I will, but the company will pay.

The sharing of information between companies has increased, which is extremely important. As well, with the new tracking system that will be put in place, we will be able to ensure with regard to those who are moving money monthly, $10,000 or more, or $1 million a month or $12 million a year, that we can assess the risks and focus on them and find solutions. We will be able to see if a lot of activity is happening with one company or 10 companies.

Objectively, Bill C-82 would ensure that companies and individuals that need to pay their taxes will pay them so that the Canadian government can—

[Erin Weir, Independent, Regina—Lewvan, SK]

Mr. Speaker, this is a very esoteric topic, and I think it makes sense to talk about tangible examples.

I spent this past weekend in Saskatoon at the Saskatchewan NDP convention. One of the largest companies in that city is Cameco, which mines uranium in the northern part of the province. For many years, it had a contract with its own subsidiary, in Zug, Switzerland, to sell uranium for the rock-bottom price of only $10 per pound. The uranium was not being consumed in Switzerland. The whole point of this arrangement was to transfer profits from Canada to Switzerland, avoiding hundreds of millions of dollars in corporate tax both federally and in the Province of Saskatchewan.

Could the member for Sackville—Preston—Chezzetcook explain to us how Bill C-82 would help to stop companies from engaging in that type of tax avoidance?

[Darrell Samson, Liberal, Sackville—Preston—Chezzetcook, NS]

Mr. Speaker, I am pleased to be back in the House this morning after our constituency week. Constituency weeks give us a chance to spend time with people in our communities, which is incredibly important work.

It is a pleasure for me to speak to Bill C-82 this morning. It is definitely another clear step by our government in moving forward on taxes and fairness. When I say fairness, it is extremely important to realize that the tax loopholes that exist need to be shut when it comes to international base erosion and profit shifting. We are seeing wealthy individuals or businesses moving their money to countries where low taxes are available to them, and Canadians lose out on those revenues. That is crucial. For example, many programs we offer to our people we will not be able to continue or improve if money keeps flowing outside the country.

For example, there was nothing better than this week when I went around and heard veterans indicating how happy they are that our government brought back the pension for life. That is something they were asking for over a number of years that is very important to them. I hear veterans talk about the $40,000 education investment or the $80,000 four-year education investment. Those are major investments for veterans.

I was chatting not so long ago with some youth about what our government has done thus far to help and work with them. We underlined, of course, that we doubled the Canada summer jobs for individuals. We also created the youth Canada program, where we hired 870 young people on the ground for competitive co-op programs or internships. We can talk about the 1,200 green jobs for young people under STEM, which is science, technology, engineering and math.

This is very good legislation. It would continue our philosophy of ensuring that we can continue to offer programs for Canadians.

This multilateral convention came about when the OECD and G20 countries worked together to look at base erosion and profit shifting. While they were doing that, they realized that many of the tax treaties that existed had many loopholes and some challenges. Trying to find solutions for each and every one in all the countries involved would be time consuming, very costly and probably not very efficient. Because of that, they brought forward this framework, this multilateral convention, which is a framework for countries to move forward quickly and effectively. Our government signed on to it on June 7, 2017, and then, of course, we tabled it in the House in January 2018.

It is not just Canada. Over 100 countries have already signed on to this, because they know that this is an area they need to streamline so they can continue to grow and prosper.

Talking about growth and prosperity, we need to talk about our country. Of course, we have created over half a million jobs in the last two and a half years. That is an enormous increase in jobs. We have the lowest unemployment rate in the last 40 years. That is again an indication of the strength of this country, and it puts us in a great position to continue to grow and prosper, and we are going to take advantage of it. This is an opportunity, not a challenge, in that way. We will crack down on these programs to ensure that the revenues due to Canadians are there so we can reinvest them for the middle class and for Canadians. That is our objective.

This important multilateral convention would deal with three major fronts. The first one would modify existing tax treaties. It is extremely important to look at the loopholes and see how we can find solutions and bring them forward. However, we have also added minimum standards for the abuse of tax treaties. There is lots of abuse, so how we deal with those abuses is key. First are the loopholes. Second is finding tools or rules to reduce those abuses. That is what countries will have to find solutions for.

I want to talk about the minimum standards that focus on dispute resolution and arbitration. We have to make sure that there is dispute resolution where the objective is to find a solution. Instead of being very costly and fighting in court, we need to find a way to work together to find solutions that are acceptable and that ensure that Canadians receive the funds they are supposed to and can reinvest those funds in social programs for the middle class and less fortunate Canadians.

Tax fairness is our objective, and this would move another step closer to what we have introduced throughout the two and a half years the Liberals have been in government. I have to talk about the fact that we cut taxes for the middle class and raised taxes for the wealthiest one per cent. There were two objectives. One was to reduce taxes for the middle class and to increase those for the most fortunate, which is extremely important.

When I speak to young families in my riding about the Canada child benefit program, they recognize how important that investment is in their families for their children. It is essential. It is very touching to hear young families share that information, and it is not just in my riding but right across the country. In the riding of Sackville—Preston—Chezzetcook, which I represent, $5.2 million per month—yes, everyone heard me correctly, $5.2 million per month—goes to young families. That represents $60 million a year. If we multiply that by 338 members, everyone can see how much investment our government is putting into this important area.

This is Small Business Week, so we should be talking about small businesses and what our government has done to continue to improve the environment for small businesses to prosper. When we came into power, the tax rate was 11%. We reduced it to 10.5%, then 10%, and in April, we will reduce it once again to 9%. What does 9% represent? That 9% means that with the federal, provincial and territorial taxes together, it will be only 12%, which is the lowest in the G7 and one of the lowest in the OECD as well.

In conclusion, the money we invested, over $1 billion, in budgets 2016, 2017 and 2018 was to enhance a new program that will allow us to track closely any transactions of $10,000 or more that move about monthly. How big is this? It is very big. A million transactions per month is 12 million transactions of $10,000. We work closely with other countries to make sure that we share the information about foreign banking.

I am extremely happy to be here today to speak to this bill that will continue to allow Canadians and our government to support the middle class and ensure that there are jobs and programs as we move forward in a strong country.

[Francesco Sorbara, Liberal, Vaughan—Woodbridge, ON]

Mr. Speaker, in the first three budgets that our government brought forward, we invested about $1 billion into CRA to ensure that we keep an eye on aggressive tax-planning techniques or programs and tax avoidance. We are fighting those things and Bill C-82 is another large step in that direction.

As the member knows, tax planning is complex and tax measures need to be looked at. We have looked at certain tax expenditures in our budgets. For example, the multiplication of the small business tax deduction was something we eliminated so that people would not take advantage of it in ways it was not meant for.

Our government has invested a serious amount of funds, over $1 billion, into CRA to combat tax avoidance and tax evasion. We have also looked at our tax code with the goal of simplifying it. I personally feel that we have done a terrific job. There is always much work to do on all files. That is what life is about working in government, and what we all do here on a daily basis, but we need to ensure that we continue on as such.

[Francesco Sorbara, Liberal, Vaughan—Woodbridge, ON]

Mr. Speaker, I will be splitting my time with my friend and colleague from the east coast from the riding of Sackville—Preston—Chezzetcook. It is great to see him in the House this morning.

It is great to be back in the House this morning and to hear some of the debate. It is not so great to hear the level of discourse coming from members on the other side, the opposition benches, where they will stay for a very long time if they continue as such. I say that through you, Mr. Speaker, to my friend from Carleton, who I sit on the finance committee with.

Bill C-82, an act to implement a multilateral convention to implement tax treaty-related measures to prevent base erosion and profit shifting, is one of those international accords we can all applaud. We can also applaud the tax cut for nine million Canadians, which brought about $20 billion in tax savings over a four-year period, or about $550 per year per couple. To a working couple benefiting from our tax cut for middle-class Canadians, $550 is a substantial amount of money. It helps pay for many activities for their kids. It helps put gas in their vehicle and to buy groceries and so forth. It is too bad the Conservatives voted against that, and I think they need to be held to account for that. It is too bad they also voted against the Canada child benefit, which benefits nine out of 10 Canadian families, representing an average of $2,300 more. In my riding of Vaughan—Woodbridge, I consistently hear about how the Canada child benefit is helping families fund their kids' day-to-day activities.

It was also noted about what is called “refundable” or “non-refundable” tax credits. A lot of the boutique tax credits the opposition party member referenced in his comments were ones working middle-class Canadians could not take advantage of because they did not have taxes payable, and only benefited wealthier working Canadians. It is a little fact that was missed.

Turning to Bill C-82, OECD Secretary-General Angel Gurría said the following:

The conclusion of this multilateral instrument marks a new turning point in tax treaty history. We are moving towards rapid implementation of the far-reaching reforms agreed under the BEPS Project in more than 1,200 tax treaties worldwide. In addition to saving the signatories form the burden of bilaterally renegotiating these treaties, the Convention will result in more certainty and predictability for businesses and a better functioning international tax system for the benefit of our citizens.

Bill C-82 basically follows our government agenda from budget 2016. In chapter 8, we talked about making our tax system fairer, simpler, more efficient and also ensuring all organizations, enterprises and high net worth individuals follow the tax rules that everyday businesses and people in my riding follow. It is great to see Bill C-82 come to the House for approval, and it is great to see our party is shepherding this as quickly as possible.

On a personal note, I sat on the Canadian Institute of Chartered Accountants user advisory council for a number of years. I understand full well the importance of working with our international partners at various accounting institutions in the world, and also with our partners for multilateral purposes, including the base erosion and profit shifting deal.

To give an indication of the annual losses that are occurring, the OECD estimates 10% of global corporate taxing income, or approximately $100 billion to $240 billion is lost, where little or no overall corporate tax is being paid. This agreement is far-reaching. Working together in the OECD G20 BEPS project, over 60 countries developed 15 actions to tackle tax avoidance, improve the coherence of international tax rules and ensure a more transparent tax environment. Leaders of OECD and G20 countries, as well as other leaders, urge the timely implementation of this comprehensive BEPS package.

That information comes right from the document I was reading over the weekend on the multilateral convention to implement tax treaty-related measures to prevent BEPS from OECD. I encourage my colleagues to read it because it is an interesting document.

It pertains to our economy and ensuring we have a strong middle class and that we continue to help those who are working hard to join the middle class. It pertains to ensuring that all corporations in Canada with operations in the world and vice versa, those foreign entities that operate in Canada domestically, pay their fair share, much like all our residents do in each of our ridings. With that, it is great to stand up and speak to Bill C-82.

Taxes paid by Canadians are what fund the programs and services that make our country thrive. When the wealthy use international tax avoidance schemes to avoid paying what they owe, it is the hard-working middle class, those folks in my riding of Vaughan—Woodbridge, who foot the bill. That is unacceptable.

Tax fairness continues to be a cornerstone of our government's promise to Canadians to grow a stronger middle class. In each of our three budgets, the government has passed laws on both the international and domestic fronts to enhance the integrity of Canada's tax system and give greater confidence that the system is fair for everyone. I encourage some of the opposition folks here this morning to look at our budgets. They are actually great documents that pertain to tax fairness for all Canadians, especially with respect to putting in resources. Over $1 billion was invested in the CRA, after those many years of cuts by the Conservatives. The Conservatives are synonymous with cuts to the system and the CRA. We want to ensure that all institutions in Canada are paying their fair share, because we know all hard-working Canadians go to work, pay their fair share of taxes, and want to make sure they create a better standard of living for their families and a better future for their children and for all Canadians.

Since our first budget in 2016, the government has continually strengthened the ability of the CRA to crack down on tax evasion and combat tax avoidance with increased funding. This funding has supported transformational changes to the CRA's compliance programs, allowing them to better target those posing the highest risk of tax avoidance, and more effectively fight tax evasion and aggressive tax avoidance.

Today we take another step toward levelling the playing field and ensuring all Canadians pay their fair share of taxes. With this legislation, the Government of Canada is upping the ante in the fight against aggressive international tax avoidance and safeguarding the government's ability to invest in the programs and services that help the middle class and people working hard to join it. Whether it is putting in place a 10% increase in the guaranteed income supplement for our most vulnerable seniors, increasing the Canada workers benefit for those hard-working Canadians at the lower end, giving them that bump up, that extra few hundred dollars a year to make a big difference in their lives, we are doing those things while ensuring that our tax system is sound, efficient and fair for all Canadians and all Canadian organizations.

Ensuring tax fairness is complex. I know that for a fact because I sat on the CICA user advisory council. Understanding tax and accounting language does require a certain amount of specialization. It requires that we work with a wide range of partners at home and around the world, which is what we have done with the legislation we are debating today.

Bill C-82 would implement treaty-related measures to counter base erosion and profit shifting, also known by its acronym BEPS. This term refers to tax avoidance strategies through which businesses and wealthy individuals can use gaps and loopholes in tax rules to shift profits inappropriately to low-tax or no-tax locations. It would also ensure that transfer pricing is done fairly.

My riding is blessed with entrepreneurs of all different stripes. The city of Vaughan has over 11,000 SMEs. We have some of the most successful entrepreneurs in the country. I applaud their efforts. I meet with them regularly. I like to listen to what is working to ensure they have the skills and resources for their workers and that they can invest in their Canadian operations, and they are doing that.

That is why our unemployment rate is at a 40-year low. That is why our growth rate is near 3%. That is why firms across the world are choosing Canada to invest in. I am proud of that. However, we also need to make sure that our social programs are funded, that investments are made in early learning, that we enhance the Canada pension plan, that we reduce taxes for nine million Canadians. Yes, we ask those who are very fortunate and privileged in our society, those who are doing well, to pay a bit more. I think that is fair. I wish my colleagues on the opposition benches would appreciate that as well.

With that, I would like to close by saying that Bill C-82 is a good piece of legislation. It concerns an instrument that has recently been ratified by our counterparts, by many European countries, by France, Australia, Singapore, and some of the South Asian countries which have also adopted it in the last few weeks.

It is something that moves the needle forward on combatting aggressive tax avoidance and tax evasion, which is something good for our society. It makes our society fairer but at the same time allows those companies and corporations that do the right thing day in and day out to make the right decisions for their employees and their employees' families. I will end with that.

The House resumed from September 28 consideration of the motion that Bill C-82, An Act to implement a multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting, be read the second time and referred to a committee.

Business of the House

[Bardish Chagger, Liberal, Leader of the Government in the House of Commons]

Mr. Speaker, this afternoon we will continue second reading of Bill C-78, the family justice act. Tomorrow we will begin debate at third reading of Bill C-79, the comprehensive and progressive agreement for trans-Pacific partnership implementation act.

Next week, members will be working with Canadians in their ridings. When we return, we will begin debate on Senate amendments to Bill C-65, the harassment prevention act. Priority will then be given to the following bills: Bill C-77 on the Victims Bill of Rights and Bill C-82, the multilateral instrument in respect of tax conventions act.

Lastly, I would like to take this opportunity to wish all of my colleagues and their families a happy Thanksgiving.

[Pat Kelly, Conservative, Calgary Rocky Ridge, AB]

Thank you.

I'm going to turn to Mr. Lesage from Collectif Échec aux paradis fiscaux.

Parliament has recently been seized with this issue. We had debate on Bill C-82 last week. Do you have any data on the size or scale of the problem of tax evasion through tax havens?

This is illegal activity that we're talking about. It is always difficult to quantify and difficult to understand what we're dealing with because the whole essence of the problem is to evade detection. However, can you share with this committee what you believe is the size and scale of the problem?

Bill C-82—Notice of time allocation motion

[Bardish Chagger, Liberal, Leader of the Government in the House of Commons]

Madam Speaker, this is unfortunate because I know we can find a way, but an agreement could not be reached under the provisions of Standing Order 78(1) or 78(2) with respect to the second reading 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.

Under the provisions of Standing Order 78(3), I give notice that a minister of the Crown will propose at the next sitting a motion to allot a specific number of days or hours for the consideration and disposal of proceedings at the said stage.