Our treaty policy is to achieve shared taxation of pensions. We like to tax pensions from all sources. We also like to withhold on pensions paid to non-residents in Canada to the extent that they contributed to the pension system here in Canada, with tax-assisted RSPs and the like. We like to achieve 15%.
In the case of Hong Kong, we could not agree. The agreement reflects the fact that we will apply our domestic law, which in our case calls for withholding tax at 25%.
In the case of Namibia, tax at source is suppressed to the extent that the amount is taxable in a residence country. That's the treaty with Namibia.