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International Trade committee  On cross-border dividend payments, the protocol includes some technical adjustments that update the language in some cases and accommodate particular situations. But there is no change of substance to the possibility of imposing withholding tax on dividends, and Canada domestical

December 6th, 2007Committee meeting

Lawrence Purdy

International Trade committee  Thank you, Chair. Within the bill itself, there are indeed two references to the schedule. The first one, in clause 1, is merely for purposes of reference within the bill. The actual material change is made by this clause 4, which actually adds schedule VI to the existing schedu

December 6th, 2007Committee meeting

Lawrence Purdy

International Trade committee  I wonder if I might just add a word. I think you asked about the maximum language in the treaty, that is, the maximum rate being 10%, and whether there might be other rates applying. Statutorily, the rate that's applied under our Income Tax Act is 25% in 12 payments of interest

December 6th, 2007Committee meeting

Lawrence Purdy

International Trade committee  It doesn't matter whether the recipient is an individual, an actual person, or a corporation, the fixed rate under our act is 25%, and then it's 10% under the treaty.

December 6th, 2007Committee meeting

Lawrence Purdy

International Trade committee  Yes, assuming that none of the exemptions Mr. Ernewein described apply and the tax therefore does apply, you as the payer of the interest are required to withhold from the amount you pay the amount of tax owing.

December 6th, 2007Committee meeting

Lawrence Purdy

International Trade committee  In a legal sense the tax is being paid by the non-resident, so in the non-resident's home country the non-resident will typically get a tax credit for the Canadian withholding tax that has applied. But your question points to an important aspect of this. In economic terms, altho

December 6th, 2007Committee meeting

Lawrence Purdy

Finance committee  In some countries the boundary line lies in a different place from where it lies in Canada along the spectrum between policy and administration, so it may be the case that some other countries would be represented in an exercise like that by their finance ministries, but in the c

May 15th, 2007Committee meeting

Lawrence Purdy

Finance committee  I'm not aware of any specific requests having come from the Canada Revenue Agency in connection with the call you're describing or the working group. Certainly there's an ongoing relationship at the working level between the revenue agency and the finance department in terms of t

May 15th, 2007Committee meeting

Lawrence Purdy

Finance committee  It's certainly true that especially where international tax evasion—and I say that deliberately to distinguish it from avoidance—is involved, international cooperation is vital. The OECD has actually been playing a role for some ten years in helping to coordinate the efforts of i

May 15th, 2007Committee meeting

Lawrence Purdy

Finance committee  No. I believe the group you're referring to is a group of tax administrators, so it includes the Canada Revenue Agency on the part of Canada and their equivalents in the other countries.

May 15th, 2007Committee meeting

Lawrence Purdy

Finance committee  To answer the first part of your question, the situation in Australia bears many comparisons to Canada on a lot of different fronts, including taxation. Historically, Australia and Canada have operated very similar systems. Indeed, many aspects of the Australian system were patte

May 15th, 2007Committee meeting

Lawrence Purdy