Finance committee  It's indicating that countries have the option of listing all or part of their treaty network, and is just giving one example of why a country may choose not to list a particular agreement. For example, I would say that includes the government's decision not to list Switzerland a

Finance committee  To my knowledge, when it goes through the treaty process through the mutual agreement procedure, I do not think the settlement itself is made public. To the extent that it's a public company, I suppose any changes in their public financial statements would be public, but it's a g

Finance committee  In some senses, I think the government took a very prudent approach originally, because there was a relatively short time frame between the completion of the multilateral convention and the initial signing ceremony and there was a desire to ensure that there would be sufficient t

Finance committee  One thing to clarify is that generally speaking I think for the convention itself, it's main target is actually tax avoidance as opposed to tax evasion. It's generally looking at transactions that, while legal, push the boundaries and go beyond the intention of what the parties w

Finance committee  Yes, it does. I think the main feature of this is to provide for an anti-treaty abuse rule, in this case the principal purpose test. Combined with the new language to be included in the preamble of tax treaties, I think that's a significant tool for Canada that, hopefully, our co

Finance committee  Yes.

Finance committee  Canada has signed 23 tax information exchange agreements. With respect to the scope of this multilateral convention, no, it's not going to solve all of the problems of tax evasion. It's important to note that the scope of this convention is to deal with situations where inappropr

Finance committee  Unfortunately, we don't have specific numbers with us here today. I think one of the things that we can do is to provide some numbers with respect to a couple of recent cases the government lost in respect of treaty shopping, and cases for which we would hope that the anti-abuse

Finance committee  The way the multilateral convention works is that once you have opted into provisions, you cannot then change your mind and withdraw from them. The other impact is that the government would always have the choice to terminate the MLI, and would stop on a go-forward basis any amen

Finance committee  To address the last question first, the way the convention is structured, you cannot opt out once you have opted in. In part, that also part, influenced the prudent approach taken by the government with respect to adopting the provisions of the MLI. Once you choose them, you have

Finance committee  That is correct, because it would be the entire convention itself that Parliament would adopt and Canada would ratify.

Finance committee  The effect of not participating means that those provisions would not apply to Canada's tax treaties through the MLI.

Finance committee  The policy reason, in general, for not applying the permanent establishment provisions through the MLI is that they are very detailed, with very complicated compatibility clauses. Because Canada has such a large treaty network, we were concerned about the complexity and uncertain

Finance committee  No, unfortunately. It is not a minimum standard provision. Therefore, countries have the option of whether to opt in or not to binding mandatory arbitration. Of the 87 signatories, I think it's 26, but I could be off by one or two. Between 25 and 30 signatories have agreed to bin

Finance committee  Generally speaking I would say that all of Canada's largest trading partners have agreed to binding mandatory arbitration. In particular, it was something that G7 countries are very supportive of. The countries with whom we have the largest number of MAP cases, mutual agreement p