I’m going to answer in English, because I want to make sure I use the right terminology.
I think there were three issues raised.
The first is the distinction between tax evasion and tax avoidance. Tax evasion is, of course, a crime, and it's dealt with largely through information sharing. Tax avoidance is the legal avoidance of tax. Where it is aggressive or inappropriate tax avoidance, then typically the government responds and tries to shut it down.
The question, of course, is absolutely correct and, I think, insightful. There are greater opportunities for international tax avoidance, depending upon the size of the enterprise. That is, for example, part of the reason pillar two—the global minimum tax, which would serve to impose a minimum tax rate of 15% on all the companies within a multinational group, regardless of what country they're in—applies only to the largest multinational organizations, those with gross revenues in excess of 750 billion euros. Those rules apply to the largest companies, not only in response to the fact that they have the capacity to bear the additional compliance burden but also out of recognition that they do more of this type of planning. It would provide the greatest impact fiscally.
Finally, in terms of the specific regulation mentioned, I believe the question relates to our exempt surplus system. That is a set of rules within the Canadian income tax system that allows active business income earned in a treaty partner or tax information exchange agreement country to be repatriated to Canada tax-free. The policy underlying that set of rules allows Canadian businesses to compete on a level playing field with their competitors in foreign jurisdictions.
If there's tax imposed in the foreign country on that active business income, then that is the tax that applies. It's called a territorial system, where Canada taxes our companies on their worldwide incomes, but active business income earned in our treaty partners and in tax information exchange agreement partners can be repatriated tax-free. That allows for a level playing field and a separation of taxing rights between Canada and other countries.
Finally, I think it's important to note that it applies only to active business income. It doesn't apply to passive income. Those are the kinds of passive investment returns that can be more easily shifted to a foreign jurisdiction, and those are taxed on a current or accrual basis in Canada under what are called our foreign accrual property income rules.
Effectively, tax repatriation applies to certain active business income from foreign affiliates.
I hope that answers the three parts.