GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
With reference to Article 6 of the Convention: It is understood that any right referred to in paragraph 2 shall be regarded as situated where the property to which it relates is situated or where the exploration or exploitation may take place.
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
It is understood that any right referred to in paragraph 2 shall be regarded as situated where the property to which it relates is situated or where the exploration or exploitation may take place.
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
With reference to Articles 7 and 13 of the Convention: It is understood that, notwithstanding paragraph 7 of Article 7, where items of income are dealt with in both Article 7 and paragraph 2 of Article 13 of this Convention, then the provisions of Article 7 shall apply.
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
It is understood that, notwithstanding paragraph 7 of Article 7, where items of income are dealt with in both Article 7 and paragraph 2 of Article 13 of this Convention, then the provisions of Article 7 shall apply.
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
With reference to Article 8 of the Convention: The interpretation of the term profits in paragraph 2 of Article 8 should be guided by the first sentence of paragraph 5 of the Commentary on Article 8 of the Organisation for Economic Co-Operation and Development Model Tax Convention on Income and on Capital (July 2008).
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
The interpretation of the term profits in paragraph 2 of Article 8 should be guided by the first sentence of paragraph 5 of the Commentary on Article 8 of the Organisation for Economic Co-Operation and Development Model Tax Convention on Income and on Capital (July 2008).
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — (a)
With reference to Articles 10, 11 and 12 of the Convention: It is understood that in determining, for the purposes of those Articles, whether dividends, interest or royalties are beneficially owned by a resident of New Zealand: (a) dividends, interest or royalties in respect of which a trustee is subject to tax in New Zealand; (b) dividends in respect of which a trustee would be subject to tax in New Zealand but for an exemption that applies in relation to those dividends as agreed by the competent authorities of the Contracting States; shall be treated as being beneficially owned by that trustee.
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — (a)
It is understood that in determining, for the purposes of those Articles, whether dividends, interest or royalties are beneficially owned by a resident of New Zealand: (a) dividends, interest or royalties in respect of which a trustee is subject to tax in New Zealand; (b) dividends in respect of which a trustee would be subject to tax in New Zealand but for an exemption that applies in relation to those dividends as agreed by the competent authorities of the Contracting States;
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — (a)
(a) dividends, interest or royalties in respect of which a trustee is subject to tax in New Zealand;
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — (b)
(b) dividends in respect of which a trustee would be subject to tax in New Zealand but for an exemption that applies in relation to those dividends as agreed by the competent authorities of the Contracting States;
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
shall be treated as being beneficially owned by that trustee.
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — (a)
With reference to Article 12 of the Convention: (a) It is understood that the term royalties does not include income dealt with in Article 8; (b) It is understood that the interpretation of subparagraph 3(e) should be guided by paragraph 11.6 of the Commentary on Article 12 of the Organisation for Economic Co-Operation and Development Model Tax Convention on Income and on Capital (July 2008).
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — (a)
(a) It is understood that the term royalties does not include income dealt with in Article 8;
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — (b)
(b) It is understood that the interpretation of subparagraph 3(e) should be guided by paragraph 11.6 of the Commentary on Article 12 of the Organisation for Economic Co-Operation and Development Model Tax Convention on Income and on Capital (July 2008).
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
With reference to Article 28 of the Convention: It is understood that, notwithstanding the provisions of that Article, the provisions of Articles 23 and 24 shall have effect from the date of entry into force of the Convention, without regard to the taxable period to which the matter relates.
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
It is understood that, notwithstanding the provisions of that Article, the provisions of Articles 23 and 24 shall have effect from the date of entry into force of the Convention, without regard to the taxable period to which the matter relates.
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
IN WITNESS WHEREOF the undersigned, duly authorised by their respective Governments, have signed this Protocol.
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
HAVING REGARD to the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (the “Convention”) done at Wellington 3 May 2012;
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
HAVE AGREED that the following provisions shall form an integral part of the Convention:
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
With reference to Article 17 of the Convention: It is understood that pensions paid by, or out of funds created by, the Government of New Zealand, or a political subdivision thereof to any individual in respect of services rendered to the Government of New Zealand or subdivision thereof, shall be taxable only in New Zealand. This paragraph only applies to pensions paid under a Government Superannuation Fund scheme or a National Provident Fund scheme to individuals who became members of one of these schemes prior to 1996.
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
It is understood that pensions paid by, or out of funds created by, the Government of New Zealand, or a political subdivision thereof to any individual in respect of services rendered to the Government of New Zealand or subdivision thereof, shall be taxable only in New Zealand. This paragraph only applies to pensions paid under a Government Superannuation Fund scheme or a National Provident Fund scheme to individuals who became members of one of these schemes prior to 1996.
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
Each of the Contracting States shall notify the other Contracting State, through diplomatic channels, of the completion of the procedures necessary to give this Protocol the force of law in New Zealand and in Canada, as the case may be. This Protocol shall enter into force on the date of the later of these notifications and its provisions shall have effect on the date that the Convention enters into force.
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
IN WITNESS WHEREOF the undersigned, duly authorized to that effect, have signed this Protocol.
Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income — Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
DONE in duplicate at Wellington, this 12 th day of September 2014 in the English and French languages, both texts being equally authentic. For Canada Caroline Chrétien For New Zealand Todd McLay
Proclamation Giving Notice of the Entry into Force on December 12, 2015 of the Annexed Supplementary Convention, entered into on November 18, 2014 and intended to alter the Convention between Canada and Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital — Proclamation Giving Notice of the Entry into Force on December 12, 2015 of the Annexed Supplementary Convention, entered into on November 18, 2014 and intended to alter the Convention between Canada and Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital
ELIZABETH THE SECOND, by the Grace of God of the United Kingdom, Canada and Her other Realms and Territories QUEEN, Head of the Commonwealth, Defender of the Faith.
Proclamation Giving Notice of the Entry into Force on December 12, 2015 of the Annexed Supplementary Convention, entered into on November 18, 2014 and intended to alter the Convention between Canada and Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital — Proclamation Giving Notice of the Entry into Force on December 12, 2015 of the Annexed Supplementary Convention, entered into on November 18, 2014 and intended to alter the Convention between Canada and Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital
TO ALL TO WHOM these presents shall come or whom the same may in any way concern,
Proclamation Giving Notice of the Entry into Force on December 12, 2015 of the Annexed Supplementary Convention, entered into on November 18, 2014 and intended to alter the Convention between Canada and Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital — Proclamation Giving Notice of the Entry into Force on December 12, 2015 of the Annexed Supplementary Convention, entered into on November 18, 2014 and intended to alter the Convention between Canada and Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital
Whereas, by Order in Council P.C. 2016-376 of May 20, 2016, the Governor in Council, pursuant to subsection 32(4) of An Act to implement conventions between Canada and Spain, Canada and the Republic of Austria, Canada and Italy, Canada and the Republic of Korea, Canada and the Socialist Republic of Romania and Canada and the Republic of Indonesia and agreements between Canada and Malaysia, Canada and Jamaica and Canada and Barbados and a convention between Canada and the United Kingdom of Great Britain and Northern Ireland for the avoidance of double taxation with respect to income tax, directed that a proclamation do issue giving notice of the entry into force on December 12, 2015 of the annexed supplementary convention, entered into on November 18, 2014 and intended to alter the Convention between Canada and Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital, entered into at Ottawa on November 23, 1976;
Proclamation Giving Notice of the Entry into Force on December 12, 2015 of the Annexed Supplementary Convention, entered into on November 18, 2014 and intended to alter the Convention between Canada and Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital — Proclamation Giving Notice of the Entry into Force on December 12, 2015 of the Annexed Supplementary Convention, entered into on November 18, 2014 and intended to alter the Convention between Canada and Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital
Now know you that We, by and with the advice of Our Privy Council for Canada, do by this Our proclamation give notice of the entry into force on December 12, 2015 of the annexed supplementary convention, entered into on November 18, 2014 and intended to alter the Convention between Canada and Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital, entered into at Ottawa on November 23, 1976.
Proclamation Giving Notice of the Entry into Force on December 12, 2015 of the Annexed Supplementary Convention, entered into on November 18, 2014 and intended to alter the Convention between Canada and Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital — Proclamation Giving Notice of the Entry into Force on December 12, 2015 of the Annexed Supplementary Convention, entered into on November 18, 2014 and intended to alter the Convention between Canada and Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital
Of all which Our Loving Subjects and all others whom these presents may concern are required to take notice and to govern themselves accordingly.
Proclamation Giving Notice of the Entry into Force on December 12, 2015 of the Annexed Supplementary Convention, entered into on November 18, 2014 and intended to alter the Convention between Canada and Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital — Proclamation Giving Notice of the Entry into Force on December 12, 2015 of the Annexed Supplementary Convention, entered into on November 18, 2014 and intended to alter the Convention between Canada and Spain for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital
In testimony whereof, We have caused this Our Proclamation to be published and the Great Seal of Canada to be affixed to it.