Treaties
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Canada's Tax Treaties
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Call Number: LAW LIBRARY reference room (level 2): HJ2343.C2 M245
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Status of International Tax Treaty Negotiations (Department of Finance Canada)Notices of tax treaty developments. Browse by country, status, or date.
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Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPSIn November 2016, over 100 jurisdictions concluded negotiations on the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ("Multilateral Instrument" or "MLI") that will swiftly implement a series of tax treaty measures to update international tax rules and lessen the opportunity for tax avoidance by multinational enterprises. The MLI already covers 86 jurisdictions and entered into force on 1st July 2018. Signatories include jurisdictions from all continents and all levels of development and other jurisdictions are also actively working towards signature.
Transfer Pricing
If you and another entity within your multinational group agree to buy or sell goods or services with each other, these transactions must be priced properly to ensure the appropriate amount of profit is reported in Canada Transfer pricing legislation requires that these transactions occur under arm's length terms and conditions.
Income Tax Act, RSC 1985, c 1 (5th Supp), Part XVI.1 Transfer Pricing
Exchange of Information
Exchange of information is about achieving global tax co-operation through the implementation of international tax standards and other instruments to put an end to bank secrecy and tackle tax evasion.
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OECD Exchange of InformationIncludes manuals on assistance in the collection of taxes and information exchange, model protocol to the tax information exchange agreements (TIEAs), and the exchange of tax information portal - an initiative of the Global Forum on Transparency and Exchange of Information for Tax Purposes. The Global Forum is the continuation of a forum which was created in the early 2000s in the context of the OECD’s work to address the risks to tax compliance posed by non-cooperative jurisdictions. Through an in-depth peer review process, the restructured Global Forum monitors that its members fully implement the standard of transparency and exchange of information they have committed to implement. It also works to establish a level playing field, even among countries that have not joined the Global Forum.
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Global Forum on Transparency and Exchange of Information for Tax PurposesConducts peer reviews of its member jurisdictions' ability to co-operate with other tax administrations in accordance with the internationally agreed standard. The standard provides for exchange of information on request where it is foreseeably relevant to the administration and enforcement of the domestic tax laws of the requesting jurisdiction. Effective exchange of information requires that jurisdictions ensure information is available, that it can be obtained by the tax authorities and that there are mechanisms in place allowing for the exchange of that information. The Global Forum's peer review process examines both the legal and regulatory aspects of exchange (Phase 1 reviews) and the exchange of information in practice (Phase 2). The EOI Portal will track the development of these peer reviews, including changes that jurisdictions make in response to the Global Forum's recommendations.
Base Erosion and Profit Shifting
Base erosion and profit shifting (BEPS) refers to tax avoidance strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations. Under the inclusive framework, over 100 countries and jurisdictions are collaborating to implement the BEPS measures and tackle BEPS.
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Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPSIn November 2016, over 100 jurisdictions concluded negotiations on the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ("Multilateral Instrument" or "MLI") that will swiftly implement a series of tax treaty measures to update international tax rules and lessen the opportunity for tax avoidance by multinational enterprises. The MLI already covers 86 jurisdictions and entered into force on 1st July 2018. Signatories include jurisdictions from all continents and all levels of development and other jurisdictions are also actively working towards signature.
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OECD Base Erosion and Profit ShiftingIncludes information on the OECD/G20 BEPS Project which outlines 15 actions to equip governments with domestic and international instruments to address tax avoidance, ensuring that profits are taxed where economic activities generating the profits are performed and where value is created.
