Finance committee  Yes, it's based on the OECD model tax treaty.

Finance committee  Thank you for the question. I would be happy to. This bill relates to a bilateral tax agreement between Canada and Madagascar. It's intended to both improve the administration of our tax system and reduce barriers to trade between two countries on a bilateral basis. The base erosion and profit shifting project was born out of a multilateral effort to deal with global tax avoidance—the base erosion, profit shifting and moving income around.

Finance committee  Maybe I'll give you two simple and concrete examples. A Canadian firm investing in Madagascar or vice versa would be interested to know what the withholding tax rate is on, say, dividends paid from a Madagascar subsidiary to the Canadian parent, or again, vice versa. The Canadian firm would want to have certainty as to the rate going forward over the term of the investment As noted, this treaty would ensure that the maximum withholding dividend rate on income or dividends paid by a Madagascar subsidiary to a Canadian firm, as long as they have substantial investment in their Madagascar subsidiary, would not exceed 5%.

Finance committee  We don't have the specific data on the amount of Madagascar withholding tax or taxes imposed on dividends, interest and royalties paid to Canadian taxpayers, if that's the specific question. We don't have that.

Finance committee  Right. I'm just working through that in my head. You would have, for example, dividend income from a Canadian firm from Madagascar. The question might be how much foreign tax was imposed on it that would generate support for a foreign tax credit. We can ask our colleagues in our international business income tax division to see if they have that data.

Finance committee  My colleague, Ms. Smith, made comments relating to the difficulties quantifying the economic impacts of a bilateral tax convention. I think it's generally perceived that having bilateral tax conventions between two nations improves the atmosphere for trade and breaks down barriers to trade, but it is quite difficult, if not impossible, from international experience, to precisely quantify the economic effect of a particular bilateral agreement.

Finance committee  Perhaps it would be a good idea to describe briefly the objects or intentions of the two bills and two types of treaties. The multilateral instrument is an efficient and effective way of modifying the application of existing tax treaties that are currently in force, but it is not itself a bilateral tax treaty between Canada and another country.

Finance committee  With apologies, we don't have the detailed history of the negotiations. As my colleague Stephanie said, negotiations started some time ago and concluded with the signing in November of 2016. Canada has a large number of tax treaties. This would be, I believe, the ninety-fourth. Concluding bilateral tax conventions with other countries is very much a part of how Canada does business internationally.

Finance committee  No, we do not.

Finance committee  I just conferred with my colleague. We don't know the contents of that meeting. But to reiterate something my colleague had mentioned about timing, the treaty had already been negotiated by that point. In fact, I don't know if a significant portion or all had been negotiated under the previous government.

Finance committee  No, we do not.

Finance committee  No, I do not. My colleague helpfully reminded me that perhaps I was a bit vague in my description of when the treaty was signed. It was November 24, 2016.

Finance committee  Thank you, Chair. We're appearing before the committee today to speak about Bill S-6, an act to implement the convention between Canada and the Republic of Madagascar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. This bill is intended to enact into law the Canada-Madagascar tax convention, or simply, the convention.

Finance committee  I can only speak to my personal knowledge, certainly not to any of the conversations between our minister's staff and anyone not in the department. To answer your question, I'm not aware of any mention of SNC-Lavalin in the context of Bill C-82. You asked, though, whether there could be any benefit under Bill C-82 for companies like SNC-Lavalin, Canadian companies competing abroad.

Finance committee  I have not, but I don't wish to overstate my involvement in the development of the multilateral instrument. I was involved in the preparation of the legislation, or the bill, before the committee right now, but—