Canada
A. Progress in the implementation of the minimum standard
Canada has 94 tax agreements in force,1 as reported in its response to the Peer Review questionnaire. Thirty-six of those agreements comply with the minimum standard.
Canada signed the MLI in 2017 and deposited its instrument of ratification on 29 August 2019. The MLI entered into force for Canada on 1 December 2019. The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect.
Canada indicated in its response to the Peer Review questionnaire that steps have been taken (other than under the MLI) to implement the minimum standard in the agreements with Brazil, Germany, Norway, Switzerland and the United States.
Canada is implementing the minimum standard through the inclusion of the preamble statement and the PPT.2
← 1. This includes an Arrangement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income between the Canadian Trade Office in Taipei and the Taipei Economic and Cultural Office in Canada.
← 2. For its agreements listed under the MLI, Canada is implementing the preamble statement (Article 6 of the MLI) and the PPT (Article 7 of the MLI). Canada expressed a statement, in accordance with Article 7(17)(a) of the MLI, that while it accepts the application of PPT alone as an interim measure, it intends where possible to adopt an LOB provision in addition to or in replacement of the PPT through bilateral negotiation.