Canada Signs Its First Tax Information Exchange Agreement

Copyright 2009, Blake, Cassels & Graydon LLP

Originally published in Blakes Bulletin on Tax, September 2009

On August 29, 2009, Canada signed its first tax information exchange agreement (TIEA) with the Netherlands in respect of the Netherlands Antilles (which is specifically not covered by the tax convention between Canada and the Netherlands) (the Netherlands Antilles TIEA). A TIEA is a bilateral agreement wherein two countries agree to exchange information relevant to the administration and enforcement of their domestic tax laws. The 2007 Canadian federal budget (2007 Budget) introduced tax benefits, discussed below, for dividend payments from corporations resident in countries that do not have a tax convention with Canada but sign a TIEA with Canada. The Netherlands Antilles TIEA is based on a model agreement produced by the Organization for Economic Cooperation and Development (OECD Model Agreement).