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Finance committee  Yes. However, there are some treaties where, largely by decision of our treaty partner, they preferred to update those on a bilateral basis. In particular, we are engaging at this time in some bilateral negotiations. Those include Germany, Switzerland and Brazil.

April 2nd, 2019Committee meeting

Stephanie Smith

Finance committee  In particular, for tax evasion, the main provision in the tax treaty that will help with that is the exchange of information and the collaboration between the two tax administrations, to try to ensure that there's full information with respect to the investments between the two j

April 2nd, 2019Committee meeting

Stephanie Smith

Finance committee  I think we're moving ahead with this for the overall policy desire of expanding Canada's network of tax treaties to improve trade and investment, consistent with the fact that Canada has a number of tax treaties with African countries. I think this is consistent with the fact tha

April 2nd, 2019Committee meeting

Stephanie Smith

Finance committee  I think a significant benefit of the tax treaty with Madagascar is that it will provide for an exchange of information relationship with Madagascar, which we do not currently have. That will allow the Canada Revenue Agency to obtain information it requires in administering the Ca

April 2nd, 2019Committee meeting

Stephanie Smith

Finance committee  That question was posed earlier, and unfortunately we don't have the details with us of the entire history of the negotiations to know whether the request first came from Canada or Madagascar. There was agreement by both countries to take the negotiations forward, as evidenced by

April 2nd, 2019Committee meeting

Stephanie Smith

Finance committee  Generally I think an analysis is done by Global Affairs Canada. The information they provided to us is that the most significant sector is the mining sector. At about the time that we were preparing and moving towards signature, the most significant investment was by Sherritt Int

April 2nd, 2019Committee meeting

Stephanie Smith

Finance committee  I am not exactly sure. I believe Global Affairs does have publicly available information in respect of every country. They do an economic analysis of all countries. It's been a while since I have looked specifically at their website, so I'm not entirely sure. However, they do hav

April 2nd, 2019Committee meeting

Stephanie Smith

Finance committee  We can certainly go to the Global Affairs website and confirm the publicly available information.

April 2nd, 2019Committee meeting

Stephanie Smith

Finance committee  In discussions with CRA we are not aware of Madagascar being used as a jurisdiction for aggressive tax planning.

April 2nd, 2019Committee meeting

Stephanie Smith

Finance committee  Yes, it has. They now have a stable government in place.

April 2nd, 2019Committee meeting

Stephanie Smith

Finance committee  I am not aware of a particular study on white collar crime in Madagascar.

April 2nd, 2019Committee meeting

Stephanie Smith

Finance committee  The key way it provides for elimination of double taxation with respect to Canada is that there will be a foreign tax credit provided to a Canadian company that incurs tax in Madagascar, and that is determined in accordance with Canada's domestic foreign tax credit rules.

April 2nd, 2019Committee meeting

Stephanie Smith

Finance committee  In general, it anticipates that there could be a dispute. That's because the convention itself allocates the taxing rights. It's through, sometimes, the allocation of the taxing rights that there can be a dispute as to who has appropriately applied the tax. Sometimes there's a

April 2nd, 2019Committee meeting

Stephanie Smith

Finance committee  Yes, that's correct. That's twofold, in particular with respect to withholding taxes, because there are agreed-to reduced rates in the treaty. If we take the Canadian domestic rate of 25%, we reduce that in tax treaties. The withholding rates in Madagascar generally go up to 20%.

April 2nd, 2019Committee meeting

Stephanie Smith

Finance committee  Consistent with other tax treaties, and I think the general approach of countries worldwide, it's almost impossible to calculate the total costs and benefits of a tax treaty. That's because a tax treaty looks to improve trade and investment between two countries, and it's very di

April 2nd, 2019Committee meeting

Stephanie Smith