As part of the study, we didn't establish a causal link or correlation between the double taxation agreements with certain countries and the value of transactions reported on T106 slips in the case of transactions of related companies.
At first glance, it seems surprising that the value of transactions between related companies is higher in Barbados—given the size of its economy—than in Australia, which has a developed economy and fairly close ties with Canada. There are more transactions between Barbados and Canada than between Australia and Canada. The same is true for Bermuda, where the number of transactions is similar to the number in Australia. Bermuda is probably a very beautiful place to live and buy a second home. However, its economic activity doesn't even come close to Australia's economic activity.
Mr. Mahabir and Mr. Bernier may have more or, conversely, less information than I do on the relationship between tax treaties and transactions between related companies.