[Verse 1] Across the northern border, treaties span the globe Bilateral handshakes shake off double tax's robe When residents of two nations earn their foreign pay These parchment shields prevent the dreaded double-weigh [Chorus] OECD Model guides the way, Vienna shows us how to say What the words were meant to be, treaty language holds the key PE means permanent establishment Three-six-five rule needs assessment When the business puts down roots That's when treaty magic shoots [Verse 2] Fixed place of business anchored to the ground Six months of building makes the threshold sound Dependent agents acting in your name Transform your presence into taxing game [Chorus] OECD Model guides the way, Vienna shows us how to say What the words were meant to be, treaty language holds the key PE means permanent establishment Three-six-five rule needs assessment When the business puts down roots That's when treaty magic shoots [Bridge] Treaty shopping schemes collapse when PPT arrives Principal Purpose Test examines who survives If obtaining benefits was your main design The treaty door swings shut, no shelter you will find [Verse 3] When disputes arise between the taxing lands MAP procedure offers helping hands Mutual Agreement solves the clash Competent authorities prevent the crash [Chorus] OECD Model guides the way, Vienna shows us how to say What the words were meant to be, treaty language holds the key PE means permanent establishment Three-six-five rule needs assessment When the business puts down roots That's when treaty magic shoots [Outro] Bilateral network, worldwide web of rules Canada's treaties are the trader's tools From maple leaf to foreign shore Tax treaties even out the score
← 1 Canada's International Tax Framework | 3 Transfer Pricing →