Finance committee  In general, there is nothing in the treaty that is going to give Canada or Taiwan any additional rights to tax income. Effectively it allocates those rights between the two jurisdictions. There are no taxing rights in the agreement itself. If there were no obligation taxwise with

Finance committee  Generally, for tax credits, you look at where a person is resident, and that's generally a factual determination as opposed to a pure choice. In certain cases, for payments of interest, dividends, and royalties from a source country, there is a cap on what the source country can

Finance committee  That's correct.

Finance committee  What a treaty does would depend on the nature of what the company is doing in Taiwan, but if a Canadian company is operating in Taiwan and it hits the threshold of what is called the permanent establishment, which is set out in article 5, then the treaty sets out that yes, Taiwan

Finance committee  Depending on the nature of the relationship, the agreement would come into play. If it was a subsidiary corporation operating in Taiwan, then the agreement would come into play with respect to the transfer pricing of transactions between them, because the treaty provides that thi

Finance committee  If I understand the question, yes, we have proposed that the clarifying amendment with respect to Hong Kong would have retroactive effect, and specifically that it would come into force June 19, 2013, which is the date that the Canada-Hong Kong agreement entered into effect. Beca

Finance committee  As described by Brian, it starts with domestic laws in terms of determining who is a resident for tax purposes. Then you look to the treaty rule, which sets out a general rule on where you are resident. It is possible that you could be found resident in two different jurisdiction

Finance committee  Absolutely trade would be one of the criteria that impact the prioritization of negotiating priorities.

Finance committee  Thank you for that question. In working on the arrangement with Taiwan, because it was set up as an arrangement and it's not between two sovereign jurisdictions, in order for the Income Tax Act to apply appropriately, we needed to have certain provisions in the implementing act

Finance committee  I think it's the exact same standard that is in the model convention, article 26. In our particular treaties, I think it's in article 24 in one of them; I'm not sure specifically the article in the other. One is shorter in length than the other, but they both do the exact same

Finance committee  I'll just highlight a couple of the aspects that are included in the convention with Israel, which updates it from the version that was signed in 1975. The biggest changes, probably, are with respect to the reduction of the withholding tax rates to bring them more in line with wh

Finance committee  In general, I think the most important aspect of tax treaties that can help give the Canada Revenue Agency the tools to combat tax avoidance and tax evasion is the exchange of information with another jurisdiction. Both this arrangement and the tax treaty contain the current inte

Finance committee  In general with the negotiation process, as Brian has described, we do develop our own priorities in terms of which treaties we would like to update and whether there are new treaties, as with Taiwan. Typically, the engagement can start in two different ways. It can be at a meeti