[Verse 1] When payments flow across the line to foreign hands Section two-twelve demands its withholding stance Twenty-five percent on royalties and rent Interest, dividends - the government's intent Check the treaty rates, they might reduce the bite But collect that tax before it takes its flight [Chorus] Cross-border cash creates complications Thin cap, EIFEL, hybrid situations BEPS is watching how the profits shift Remember two-twelve's withholding gift Four rules to master when the borders blur Canadian tax law's international spur [Verse 2] Thin capitalization keeps the debt in check Section eighteen-four won't let you wreck The ratio with excessive foreign loans When debt-to-equity disrupts the zones Three-to-one's the limit, don't exceed the line Or your interest deductions will decline [Chorus] Cross-border cash creates complications Thin cap, EIFEL, hybrid situations BEPS is watching how the profits shift Remember two-twelve's withholding gift Four rules to master when the borders blur Canadian tax law's international spur [Verse 3] EIFEL's the new sheriff limiting the cost When financing expenses leave you at a loss Fixed ratio test or group ratio choice Thirty percent of income gives you voice Excessive interest gets denied or carried Tax base erosion leaves planners harried [Bridge] Hybrid mismatches play a double game Same instrument, different country's claim Debt in one jurisdiction, equity in another BEPS initiatives help nations discover Pillar One redistributes where sales occur Pillar Two ensures minimum rates concur [Chorus] Cross-border cash creates complications Thin cap, EIFEL, hybrid situations BEPS is watching how the profits shift Remember two-twelve's withholding gift Four rules to master when the borders blur Canadian tax law's international spur [Outro] From withholding tax to global minimum rate Cross-border transactions seal their fate
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