Canada
A. Progress in the implementation of the minimum standard
Canada has 94 tax agreements in force, as reported in its response to the Peer Review questionnaire. 24 of those agreements, the agreements with Australia, Austria, Belgium, Denmark, Finland, France, Iceland, India, Ireland, Israel, Japan, Lithuania, Luxembourg, Malta, the Netherlands, New Zealand, Poland, Serbia, Singapore, the Slovak Republic, Slovenia, Ukraine, the United Arab Emirates and the United Kingdom, comply with the minimum standard.
Canada signed the MLI in 2017 and deposited its instrument of ratification on 28 August 2019. The MLI entered into force for Canada on 1 December 2019. Canada has not listed its agreements with Germany and Switzerland but indicated in its response to the Peer Review questionnaire that bilateral negotiations would be pursued with respect to its agreements with Germany and Switzerland.
Canada is implementing the minimum standard through the inclusion of the preamble statement and the PPT.1
The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect.
Notes
← 1. 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 also expressed a statement, in accordance with Article 7(17)(a) of the MLI, that while it accepts the application of the PPT under the MLI, it intends where possible to adopt an LOB provision in addition to or in replacement of the PPT through bilateral negotiation.
← 2. This is 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.