Response to Andrew F. Brathwaite’s Comment

Fair point! I think though that what we have been seeing so far is analogous to the scenario where the surgeon delcares that the surgery was a success but the patient died! In this case the surgery is a simply numbers game and it will continue to be the case until there are sufficient requests for information and exchanges that are timely and provide the appropriate information. That will take years and in fact even now the OECD is making the case for the abandonment of the bilateral TIEAs in favour of their multilateral information exchange arrangement. I don’t think there will be a reversal of capital flows while we wait for a final verdict on these reviews nor do I think there is anything in the process or the rhetoric supporting it that points to a redirecting of flows to low tax, non-tax havens countries who are awaiting verification of their good standing. Take the issue with Canada now. Even without evidence or practice of exchange of information by Canada’s new Caribbean TIEA partners, Canada is happy to extent exempt surplus treatment to Canadian foreign affiliates who move to zero tax countries with no track record of transparency. So there is redirection happening already from low-tax countries with practiced compliance to zero tax with no record of compliance. Seems to me that the real agenda is not to compel adherence to transparency or modern exchange standards but to find zero-in-zero-out tax strategies to enhance the global competitiveness of Canadian companies.

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One thought on “Response to Andrew F. Brathwaite’s Comment

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