Finance committee  I can start. Unfortunately, I was just trying to pull up the treaty with Barbados so that I could confirm the reference to article XV.

Finance committee  Trevor, maybe we're best to do that, because in terms of trying to pull up both pieces of legislation, I can't off the top of my head remember. Article XV normally is about employment income, but it doesn't fit with the question.

Finance committee  If there is real, active business activity taking place in the Bahamas, which they subject to a 0% tax and whose dividends they can repatriate tax free, there would be no additional Canadian tax. That's by virtue of Canadian domestic law as opposed to operation of the tax treaty

Finance committee  I think you're referring to the domestic law provision that allows exempt surplus to be repatriated free of tax if it comes from a jurisdiction with which Canada has a tax treaty, or a tax information exchange agreement. The underlying tax policy reason for that provision is to

Finance committee  We would provide assistance if it were a question of the application of the tax treaty. If it were with respect to a particular dispute purely on Madagascar tax—

Finance committee  —we would not, but if it were a question of the application of the treaty and ensuring that there was no double tax, yes, the individual could seek assistance from the competent authority, which for Canada, under this tax treaty, is the Canada Revenue Agency.

Finance committee  We don't have the exact timing—

Finance committee  —but I do believe that it was in the early 2000s that negotiations commenced.

Finance committee  It is perhaps slightly longer than the average, but it is not uncommon for there easily to be a 10-year period from the first negotiation to signature to bringing the bill before the House.

Finance committee  On an ongoing basis, we do review both our treaty network and our outstanding negotiations to try to establish a list of priorities for new treaties, or for revising current treaties to ensure that they reflect the latest Canadian tax policy.

Finance committee  I think it's very important to being able to verify and ensure the application of the Income Tax Act. This provides them with the tool and the co-operation of the tax officials in Madagascar to provide them with the information that is needed.

Finance committee  The tax treaty itself does not provide this, particularly if you're talking about visits from Madagascar's tax officials to Canada in terms of reviewing the affairs of the particular business in Canada. It does not specifically deal with that type of co-operation. Typically, it d

Finance committee  I guess it depends on what it is. If it is Madagascar applying its domestic law in respect of a Canadian company that had operations or some investment in Madagascar, it would be the Madagascar domestic laws that would be applicable.

Finance committee  I think this goes back again to the importance of the provision that allows for the exchange of information between the two jurisdictions, which would certainly help to avoid both tax evasion and tax avoidance when it allows the Canada Revenue Agency access to the information it

Finance committee  To date, most of Canada's tax treaties will be updated through the multilateral convention, however—