Finance committee  I'm not sure I would describe it as a disadvantage, because this is a provision that will apply bilaterally. It will apply to dividends being paid both to and from Canada. Yes, if you're talking about a foreign parent company with a Canadian subsidiary, it would impose the discip

Finance committee  Generally speaking, the benefit of the mandatory arbitration provision is that it provides certainty to taxpayers that their double taxation will be resolved. Without the finality of mandatory binding arbitration, the mutual agreement procedure itself only provides that the compe

Finance committee  The negotiation of the MLI was concluded in November, 2016, and it was open for signature afterwards. Thereafter, a first signing ceremony of the multilateral convention was announced for June 2017. The government had indicated a desire to be among the first group of countries t

Finance committee  The ones that we have chosen?

Finance committee  One of the provisions that was not in the initial provisional notifications is article 4 on dual resident entities. A decision was made by the government to adopt this provision. It was generally in line with the policy and with a number of prior tax treaties that had been negoti

Finance committee  In my view, the two key aspects in this bill and in this convention are articles 6 and 7. Those are two of the rules that go towards preventing the abuse of tax treaties. I think article 6 will be very important in helping our courts interpret our tax treaties and this anti-abus

Finance committee  Our understanding is that, no, they will be able to manage such a process within their existing budget. They already have responsibility under all of these tax treaties to engage in a mutual agreement procedure, and the binding arbitration is just a final point to ensure that the

Finance committee  From an efficiency process, it would require a bilateral update of our tax treaties. Canada is a member of the OECD and the G20 and has made a commitment at the highest political levels that it endorses the outcome of the OECD/G20 project, and that it will implement the minimum s

Finance committee  We have 93 tax treaties.

Finance committee  I will give you the other 16, and I'll also indicate the ones that we would expect would be covered on final ratification. Those not currently covered but that we would expect would be covered on ratification in the final notification would include Algeria, Armenia, Ivory Coast,

Finance committee  We do not have tax treaties with the Cayman Islands or the Cook Islands. We have tax information exchange agreements with those two jurisdictions. Because tax information and exchange agreements deal only with exchange of information and this treaty itself deals with entitlement

Finance committee  It would have no impact on the Cayman Islands. That's correct.

Finance committee  When the OECD and G20 launched this BEPS process and some of the outcomes of the process required changes to tax treaties, it was recognized that for all states to include those in their tax treaties would be a very lengthy and time-consuming process, due to the requirement of bi

Finance committee  We have article 16, mutual agreement procedure, and article 17, corresponding adjustments. We have also opted into part 6 that includes articles 18 to 26. That is mandatory binding arbitration.

Finance committee  Currently, the way the convention works is that on signature, countries deposit a provisional list of tax treaties to which they would like this convention to apply. On signature, Canada provisionally listed 75 tax treaties. It is expected that on ratification this number would i