2 Tax Treaties

Canadian Tax Essentials: Personal & Corporate · 3:03

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Lyrics

[Verse 1]
Canada builds bridges across the world
Bilateral treaties, flags unfurled
To stop the double tax from taking hold
OECD Model guides the way we're told
Vienna Convention helps us read between
The lines of treaties, keeping meanings clean

[Chorus]
Treaties map the way, PPT to stay
Permanent establishment marks the day
MAP will solve disputes along the way
Bilateral bridges keep double tax at bay
Treaties map the way, that's how we play
In the global tax game every single day

[Verse 2]
Fixed place of business, six months or more
Permanent establishment opens up the door
For source country taxation rights to flow
But treaty shopping schemes, we have to know
Principal purpose test will block the game
When tax avoidance is the only aim

[Chorus]
Treaties map the way, PPT to stay
Permanent establishment marks the day
MAP will solve disputes along the way
Bilateral bridges keep double tax at bay
Treaties map the way, that's how we play
In the global tax game every single day

[Bridge]
When countries disagree on what the treaty means
Mutual Agreement Procedure cleans
The slate between the competent authorities
Working together to resolve uncertainties
Vienna rules guide interpretation's art
While OECD comments play their part

[Verse 3]
From residence to source, the treaty flows
Dividing up the tax that someone owes
But artificial structures won't succeed
When PPT examines the taxpayer's need
The network grows with each bilateral tie
Protecting taxpayers beneath the sky

[Chorus]
Treaties map the way, PPT to stay
Permanent establishment marks the day
MAP will solve disputes along the way
Bilateral bridges keep double tax at bay
Treaties map the way, that's how we play
In the global tax game every single day

[Outro]
Bilateral treaties, worldwide they spread
Keeping double taxation fears at bay instead

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