[Verse 1]
When payments cross our border line
To non-residents overseas
Section two-twelve draws the line
Withholding tax at source with ease
Twenty-five percent's the rate
Unless a treaty makes it wait
Canada keeps what's owed before
The money leaves our fiscal shore
[Chorus]
Cross-border rules, four pillars strong
Withholding, thin cap, don't get it wrong
EIFEL limits, hybrid schemes
BEPS is changing global dreams
Two-twelve, eighteen-four, remember well
These numbers have a story to tell
[Verse 2]
Thin capitalization's game
When debt-to-equity's too high
Section eighteen-four takes aim
At interest costs that reach the sky
One-and-a-half to one's the test
If you exceed, you've failed the quest
No deduction for the excess part
Thin cap rules will break your heart
[Chorus]
Cross-border rules, four pillars strong
Withholding, thin cap, don't get it wrong
EIFEL limits, hybrid schemes
BEPS is changing global dreams
Two-twelve, eighteen-four, remember well
These numbers have a story to tell
[Verse 3]
EIFEL's here with new restrictions
Excessive interest gets the axe
Thirty percent of income's friction
Is all you get for interest tax
Fixed ratio rule applies
Unless you choose the group ratios
Net interest cannot exceed
What EIFEL says you really need
[Bridge]
Hybrid mismatches try to play
Both sides of international law
Same payment, different way
Each country sees without a flaw
BEPS Pillar One divides the pie
Where profits should be taxed and why
Pillar Two sets fifteen floor
Global minimum, nothing more
[Chorus]
Cross-border rules, four pillars strong
Withholding, thin cap, don't get it wrong
EIFEL limits, hybrid schemes
BEPS is changing global dreams
Two-twelve, eighteen-four, remember well
These numbers have a story to tell
[Outro]
Canada's joined the global fight
Against base erosion's might
Four rules working hand in hand
Protecting our taxation land