Jurisdictions can also use the text of the articles in the model protocol if they wish to include the automatic and spontaneous exchange of information in a new TIEA. Download UK and Jersey Letter Exchanges (size 60kb) The interactive figure in Canada`s double taxation conventions shows countries with which Canada can exchange information on request under current tax treaties, as well as jurisdictions that have signed a previous agreement with Canada. Countries are grouped after the signing year. In practice, double taxation agreements allow Canada to exchange information on request, as long as it is reasonable to consider that this information is relevant to the application of tax rules. This information is mainly intended for income tax, but in most tax treaties, the exchange of information is also possible for other types of taxes than those specifically covered by the convention. In this regard, legal systems may be based on a bilateral agreement between the competent authority for the implementation of the automatic exchange of information in accordance with the common standard of notification or automatic exchange of reports by country on a TIEA, particularly in cases where it is not (yet) possible to automatically exchange information through the relevant authority within the framework of a relevant multilateral agreement. All agreements have been signed and ratified, unless otherwise stated. As part of the BePS (Base Erosion and Profit Shifting) action plan, the OECD recommended the implementation of National Reports (CBCR), standardised forms to be completed by multinationals with total consolidated total revenues of EUR 750 million or more. According to the OECD, the implementation of the CBCR should improve the data available for analysis and monitoring of the extent and economic impact of beps practices.
This report contains information on taxes paid, income, profits, sales, assets and the number of employees per country for each subsidiary of a multinational company. It is presented annually to the tax administration of the tax administration for the tax residence of the superior parent company. The division of the CBCR between legal systems will allow countries to gain a more complete picture of the activities of multinationals operating in their territory and will help to combat the erosion of the tax base caused by the international transfer of profits. The interactive tax information exchange mechanisms available in Canada summarize all international tax treaties in which Canada participates. Double taxation agreements are designed to avoid international double taxation and avoid income tax evasion and capital taxes. Canada`s double taxation conventions are generally designed according to the 1963 OECD convention model. It contains Article 26 on the exchange of tax information on a bilateral basis. This article governs the exchange of information on demand between contracting states. In short, it does not require tax authorities to receive information that they have not been able to obtain in accordance with their national laws, nor to provide information on the disclosure of trade, professional or professional secrets. In 2013, the OECD began developing a Common Reporting Standard (SIR) for the automatic exchange of financial account information as part of the automatic exchange of financial account information under FATCA, which introduced the automatic exchange of tax information between the United States and several countries (including major European countries and Canada) [11].