Finance committee  That's a very large question. We do cleave to our view expressed earlier that tax treaties are beneficial. I don't mean to qualify that at all. However, there is a concern sometimes, and this is the point that you're seeking to lead to, that there can be tax minimization by multi

Finance committee  We're speaking of individuals rather than corporations?

Finance committee  For individuals, very generally it's where you have the closest connections. There are “deemed” rules where if you spend so many days in Canada you may be treated as a resident, or if you're a member of the diplomatic corps you may be deemed to be a Canadian resident. Apart from

Finance committee  You can start with that, and then countries may challenge you on it. I'll ask my colleague to speak about the special rules, the specific rules we have in both of these treaties.

Finance committee  I don't think there are any issues unique to either of these agreements, or arrangement. It is possible for somebody, first of all, to make a claim to be resident in two or more countries. That's probably not something they would generally be inclined to do. It's possible for two

Finance committee  Yes, potentially it would. If a Taiwanese shareholder of a Canadian company.... If there were such a case and if it received dividends, interest, or royalties from that company, then lower withholding tax rates would apply, unlike in a case where there was no arrangement in place

Finance committee  Well, we see a value generally in having tax treaties in place because of the certainty that they provide, as we discussed earlier. In these particular cases, it's helpful for firms to know that they have this lower withholding tax, and other taxes, in place to give them certaint

Finance committee  Thank you.

Finance committee  Thank you very much. In terms of the impact of this, I think it's directly an efficient way of modifying our tax treaties to ensure that inappropriate treaty abuses are constrained. In terms of its overall impact I would situate that in the context of the so-called BEPS exercise