Finance committee  This agreement is very similar to other agreements that we have negotiated with the majority of our other treaty partners. In respect of the withholding rate, on dividends looked at from a Canadian perspective it would be reduced from the 20% domestic withholding rate in the Inco

Finance committee  Our understanding is that the majority of Canadian investment in Madagascar is in the mining sector; that is the sector of most interest for Canadians. We understand from Global Affairs Canada that there are at least five Canadian-based companies active in the Madagascar mining s

Finance committee  Okay.

Finance committee  Our understanding is that they have a tax administration that administers their tax law. They have a comprehensive tax system. and It's my understanding that it is administered as such.

Finance committee  Madagascar has a fairly small tax treaty network. I know they have a tax treaty with France. Beyond that, off the top of my head I'm not sure who else they have tax treaties with.

Finance committee  They are similar, yes.

Finance committee  The best answer is that while the treaty was actually negotiated a number of years ago, it was not further advanced because of the political instability in Madagascar. It was only after there was more political stability that efforts were renewed, leading to the signature of the

Finance committee  That's correct.

Finance committee  In responding to the question, it might be helpful to clarify the taxes that are within the scope of this double taxation agreement for Canada. It includes taxes on income under the Income Tax Act. In respect of Madagascar, it includes the tax on income, the synthetic tax, the di

Finance committee  I am not aware of any specific carbon tax plan in Madagascar.

Finance committee  Consistent with other tax treaties, and I think the general approach of countries worldwide, it's almost impossible to calculate the total costs and benefits of a tax treaty. That's because a tax treaty looks to improve trade and investment between two countries, and it's very di

Finance committee  We have not done any economic analysis of the existing situation with respect to trade and investment with Madagascar, or attempted to cost that.

Finance committee  The key way it provides for elimination of double taxation with respect to Canada is that there will be a foreign tax credit provided to a Canadian company that incurs tax in Madagascar, and that is determined in accordance with Canada's domestic foreign tax credit rules.

Finance committee  In general, it anticipates that there could be a dispute. That's because the convention itself allocates the taxing rights. It's through, sometimes, the allocation of the taxing rights that there can be a dispute as to who has appropriately applied the tax. Sometimes there's a

Finance committee  Yes, that's correct. That's twofold, in particular with respect to withholding taxes, because there are agreed-to reduced rates in the treaty. If we take the Canadian domestic rate of 25%, we reduce that in tax treaties. The withholding rates in Madagascar generally go up to 20%.