Canada has signed 23 tax information exchange agreements. With respect to the scope of this multilateral convention, no, it's not going to solve all of the problems of tax evasion. It's important to note that the scope of this convention is to deal with situations where inappropriate treaty benefits have been granted, and it's trying to deal with that scope of the problem. Tax information exchange agreements are not part of the scope of this agreement because they do not themselves provide any tax treaty benefits.
For example, with regard to the provision on obtaining the lower rate of withholding tax with respect to the Cayman Islands, there is nothing in the tax information exchange agreement, the TIEA, with the Cayman Islands that provides for a reduction of the dividend withholding tax. A dividend paid to a resident of the Cayman Islands is subject to the domestic rate of 25%. The tax information exchange agreement only provides for the exchange of information between the two jurisdictions.
There are no treaty benefits in and of themselves in the TIEA, and that's the reason for its being outside the scope of this agreement. It would have no impact. Even if you had it as part of the tax information exchange agreement, there are just no provisions to which it could apply. A tax treaty and a tax information exchange agreement are different. They're just very different instruments with different purposes.