Canada has a very large treaty network—close to 100 treaties. Certain benefits can be obtained under these tax treaties. These could be reduced withholding tax rates; they could be exemptions from tax, say, on the sale of properties. Internationally, as part of the base erosion and profit shifting process, a number of countries came together and looked at how best to address problems created by multinational or international organizations shifting their profits into low- or no-tax jurisdictions and thereby inappropriately obtaining benefits under these treaties. All sorts of benefits can be obtained in the tax world; not all of them are delivered under treaties, but some are.
As part of this process, a number of countries came together and looked at ways to address this base erosion and profit shifting. This particular measure deals with treaties. A couple of issues came up. One is that many of the treaties say that their purpose is to prevent double taxation but don't specifically mention preventing no taxation. Two, many of them don't have anti-treaty abuse provisions. Those are the two big anti-avoidance ones.
With the number of countries involved, one can imagine the number of treaties involved. Canada alone has close to 100, as I said. It would have taken a tremendous amount of time and resources to update all of our treaties. Of course, if you could picture trying to squeeze a handful of sand, if we updated a small number of treaties, tax planners could then move to the ones we haven't got to yet. So a coordinated effort was undertaken and this is the result. In an efficient manner, and only in respect of countries with whom we have a bilateral match, it would update our tax treaties to prevent this type of inappropriate tax planning and help protect the tax base.