GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 5
5 For the purposes of this Article, profits, income or gains of a resident of a Contracting State which are taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 The nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances are or may be subjected.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 3
3 Nothing in this Article shall be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 4
4 Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of a third State, are or may be subjected.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 5
5 In this Article, the term taxation means taxes which are the subject of this Convention.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, address to the competent authority of the Contracting State of which he is a resident an application in writing stating the grounds for claiming the revision of such taxation. To be admissible, the said application must be submitted within two years from the first notification of the action which gives rise to taxation not in accordance with the Convention.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 The competent authority referred to in paragraph 1 shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation not in accordance with the Convention.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 3
3 A Contracting State shall not, after the expiry of the time limits provided in its national laws and, in any case, after five years from the end of the taxable period in which the income concerned has accrued, increase the tax base of a resident of either of the Contracting States by including therein items of income which have also been charged to tax in the other Contracting State. This paragraph shall not apply in the case of fraud, wilful default or neglect.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 4
4 The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Convention.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 5
5 The competent authorities of the Contracting States may consult together for the elimination of double taxation in cases not provided for in the Convention and may communicate with each other directly for the purpose of applying the Convention.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Convention or of the domestic laws of the Contracting States concerning taxes covered by the Convention insofar as the taxation thereunder is not contrary to the Convention. The exchange of information is not restricted by Article 1. Any information received by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment or collection of, the enforcement in respect of, or the determination of appeals in relation to, the taxes covered by the Convention. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 Nothing in paragraph 1 shall be construed so as to impose on a Contracting State the obligation: (a) to carry out administrative measures at variance with the laws or the administrative practice of that or of the other Contracting State; (b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; (c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy ( ordre public ).
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
(a) to carry out administrative measures at variance with the laws or the administrative practice of that or of the other Contracting State;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (b)
(b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (c)
(c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy ( ordre public ).
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 3
3 If information is requested by a Contracting State in accordance with this Article, the other Contracting State shall endeavour to obtain the information to which the request relates in the same way as if its own taxation was involved notwithstanding the fact that the other State does not, at that time, need such information. If specifically requested by the competent authority of a Contracting State, the competent authority of the other Contracting State shall endeavour to provide information under this Article in the form requested, such as depositions of witnesses and copies of unedited original documents (including books, papers, statements, records, accounts or writings), to the same extent such depositions and documents can be obtained under the laws and administrative practices of that other State with respect to its own taxes.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 Nothing in this Convention shall affect the fiscal privileges of diplomatic agents or consular officers under the general rules of international law or under the provisions of special agreements.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 Notwithstanding Article 4, an individual who is a member of a diplomatic mission, consular post or permanent mission of a Contracting State which is situated in the other Contracting State or in a third State shall be deemed for the purposes of the Convention to be a resident of the sending State if he is liable in the sending State to the same obligations in relation to tax on his total income as are residents of that sending State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 3
3 The Convention shall not apply to international organizations, to organs or officials thereof and to persons who are members of a diplomatic mission, consular post or permanent mission of a third State or a group of States, being present in a Contracting State and who are not liable in either Contracting State to the same obligations in relation to tax on their total income as are residents thereof.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 The provisions of this Convention shall not be construed to restrict in any manner any exemption, allowance, credit or other deduction accorded: (a) by the laws of a Contracting State in the determination of the tax imposed by that State; or (b) by any other agreement entered into by a Contracting State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
(a) by the laws of a Contracting State in the determination of the tax imposed by that State; or
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (b)
(b) by any other agreement entered into by a Contracting State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 Nothing in the Convention shall be construed as preventing Canada from imposing a tax on amounts included in the income of a resident of Canada with respect to a partnership, trust, or controlled foreign affiliate, in which he has an interest.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 3
3 The Convention shall not apply to any company, trust or partnership that is a resident of a Contracting State and is beneficially owned or controlled directly or indirectly by one or more persons who are not residents of that State, if the amount of the tax imposed on the income or capital of the company, trust or partnership by that State is substantially lower than the amount that would be imposed by that State if all of the shares of the capital stock of the company or all of the interests in the trust or partnership, as the case may be, were beneficially owned by one or more individuals who were residents of that State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 This Convention shall be ratified and the instruments of ratification shall be exchanged.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 The Convention shall enter into force upon the exchange of instruments of ratification and its provisions shall have effect: (a) in respect of tax withheld at the source on amounts paid or credited to non-residents on or after the first day of January in the calendar year next following that in which the exchange of instruments of ratification takes place; and (b) in respect of other tax for taxation years beginning on or after the first day of January in the calendar year next following that in which the exchange of instruments of ratification takes places.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
(a) in respect of tax withheld at the source on amounts paid or credited to non-residents on or after the first day of January in the calendar year next following that in which the exchange of instruments of ratification takes place; and
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (b)
(b) in respect of other tax for taxation years beginning on or after the first day of January in the calendar year next following that in which the exchange of instruments of ratification takes places.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 3
3 The Agreement for the Avoidance of Double Taxation on Profits derived from Sea and Air Transportation constituted by an Exchange of Notes dated August 6, 1949 shall cease to have effect from the date this Convention takes effect in accordance with the provisions of paragraph 2 and shall terminate on the last date on which it has effect in accordance with the foregoing provisions.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
This Convention shall continue in effect indefinitely but either Contracting State may, on or before June 30 of any calendar year after the year of the exchange of instruments of ratification, give to the other Contracting State a notice of termination in writing through diplomatic channels; in such event, the Convention shall cease to have effect: (a) in respect of tax withheld at the source on amounts paid or credited to non-residents on or after the first day of January of the next following calendar year; and (b) in respect of other tax for taxation years beginning on or after the first day of January of the next following calendar year.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
(a) in respect of tax withheld at the source on amounts paid or credited to non-residents on or after the first day of January of the next following calendar year; and
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (b)
(b) in respect of other tax for taxation years beginning on or after the first day of January of the next following calendar year.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6
IN WITNESS WHEREOF the undersigned, duly authorized to that effect, have signed this Convention.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6
DONE in duplicate at Buenos Aires, this 29th day of April 1993, in the English, French and Spanish languages, each version being equally authentic. FOR THE GOVERNMENT OF CANADA: Michael Wilson FOR THE GOVERNMENT OF THE ARGENTINE REPUBLIC: Guido Di Tella
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6
FOR THE GOVERNMENT OF THE ARGENTINE REPUBLIC:
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6
At the moment of signing the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital, this day concluded between Canada and the Argentine Republic, the undersigned have agreed upon the following provisions which shall be an integral part of the Convention.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 With respect to Article 7: (a) as regards paragraph 3, it is understood that nothing contained therein shall require a Contracting State to allow the total deduction of certain expenses when they are limited in some way in the determination of profits under its domestic tax legislation or to allow the deduction of any expenditure which, by reason of its nature, is not generally allowed as a deduction under the taxation laws of that State; (b) as regards paragraph 5, the export of goods or merchandise purchased by an enterprise shall, notwithstanding the provisions of subparagraph (d) of paragraph 4 of Article 5 of the Convention, remain subject to the domestic legislation in force concerning export.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
(a) as regards paragraph 3, it is understood that nothing contained therein shall require a Contracting State to allow the total deduction of certain expenses when they are limited in some way in the determination of profits under its domestic tax legislation or to allow the deduction of any expenditure which, by reason of its nature, is not generally allowed as a deduction under the taxation laws of that State;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (b)
(b) as regards paragraph 5, the export of goods or merchandise purchased by an enterprise shall, notwithstanding the provisions of subparagraph (d) of paragraph 4 of Article 5 of the Convention, remain subject to the domestic legislation in force concerning export.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 With respect to Article 12: (a) the limitations on the taxation at source provided for under paragraph 2 are, in the case of Argentina, subject to the registration, verification and authorization requirements provided for in its domestic legislation; (b) the limitation on the taxation at source of royalties referred to in subparagraph (b) of paragraph 2 shall apply only if the royalties are derived by the author himself or his descendants; (c) in the case of payments for technical assistance the tax payable in accordance with subparagraph (c) of paragraph 2 shall be determined after the deduction of expenses for the personnel which renders the assistance in the Contracting State in which they are rendered and the costs and expenses of any equipment brought by the provider of the assistance for the specific purpose of rendering the assistance.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
(a) the limitations on the taxation at source provided for under paragraph 2 are, in the case of Argentina, subject to the registration, verification and authorization requirements provided for in its domestic legislation;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (b)
(b) the limitation on the taxation at source of royalties referred to in subparagraph (b) of paragraph 2 shall apply only if the royalties are derived by the author himself or his descendants;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (c)
(c) in the case of payments for technical assistance the tax payable in accordance with subparagraph (c) of paragraph 2 shall be determined after the deduction of expenses for the personnel which renders the assistance in the Contracting State in which they are rendered and the costs and expenses of any equipment brought by the provider of the assistance for the specific purpose of rendering the assistance.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 3
3 With respect to Article 21, it is understood that income derived by a resident of Argentina from a trust, other than a trust to which contributions were deductible, or an estate which is a resident of Canada may be taxed in Canada in accordance with its law; however, provided that the income is taxable in Argentina, the tax so charged shall not exceed 15 per cent of the gross amount of the income.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 4
4 Nothing contained in the Convention shall prevent Argentina from taxing, at the rate determined by Argentine law, the profits or income attributable to a permanent establishment maintained in Argentina by a company which is a resident of Canada. However, the total amount of tax so charged shall not exceed the income tax applied on profits of an Argentine company plus 10 per cent of such profits after deduction of such company tax.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 5
5 It is understood that the provisions of the Convention shall not be interpreted so as to prevent the application by a Contracting State of the thin capitalization provisions provided for in its domestic legislation.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 6
6 If after the date of signature of the Convention the Argentine Republic concludes a double taxation Convention with a State that is a Member country of the Organisation for Economic Co-operation and Development which limits the taxation in the country of source of payments for technical assistance referred to in Article 12 or for independent personal services performed in the absence of a fixed base referred to in paragraph 1 of Article 14, to a rate that is lower than that provided for in this Convention, the lower rate (including an exemption) shall automatically apply for the purposes of this Convention from the date of entry into force of the first-mentioned Convention.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6
IN WITNESS WHEREOF the undersigned, duly authorized to that effect, have signed this Protocol.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6
DONE in duplicate at Buenos Aires, this 29th day of April 1993, in the English, French and Spanish languages, each version being equally authentic.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 1
Short title 1 This Act may be cited as the Canada–Armenia Tax Convention Act, 2004 .
Canada–Armenia Tax Convention Act, 2004 — C-0.7 2
Definition of Convention 2 In this Act, Convention means the Convention between the Government of Canada and the Government of the Republic of Armenia set out in the schedule.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 3
Convention approved 3 The Convention is approved and has the force of law in Canada during the period that the Convention, by its terms, is in force.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 4
Inconsistent laws — general rule 4 (1) Subject to subsection (2), in the event of any inconsistency between the provisions of this Act or the Convention and the provisions of any other law, the provisions of this Act and the Convention prevail to the extent of the inconsistency. Inconsistent laws — exception (2) In the event of any inconsistency between the provisions of the Convention and the provisions of the Income Tax Conventions Interpretation Act , the provisions of that Act prevail to the extent of the inconsistency.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 5
Regulations 5 The Minister of National Revenue may make any regulations that are necessary for carrying out the Convention or for giving effect to any of its provisions.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 6
Notification 6 The Minister of Finance shall cause a notice of the day on which the Convention enters into force and of the day on which it ceases to have effect to be published in the Canada Gazette within 60 days after its entry into force or termination.
Canada–Armenia Tax Convention Act, 2004 — C-0.7
The Government of Canada and the Government of the Republic of Armenia, desiring to promote the development of economic, scientific, technical and cultural relations between both States and desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, have agreed as follows:
Canada–Armenia Tax Convention Act, 2004 — C-0.7
This Convention shall apply to persons who are residents of one or both of the Contracting States.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 1
1 This Convention shall apply to taxes on income and on capital imposed on behalf of each Contracting State, irrespective of the manner in which they are levied.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 2
2 There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages paid by enterprises, as well as taxes on capital appreciation.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 3
3 The existing taxes to which the Convention shall apply are, in particular: (a) in the case of Canada, the income and capital taxes imposed by the Government of Canada under the Income Tax Act (hereinafter referred as “Canadian tax”); and (b) in the case of Armenia, (i) the profit tax, (ii) the income tax, (iii) the property tax, (iv) the land tax (hereinafter referred to as “Armenian tax”).
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (a)
(a) in the case of Canada, the income and capital taxes imposed by the Government of Canada under the Income Tax Act (hereinafter referred as “Canadian tax”); and
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (b)
(b) in the case of Armenia, (i) the profit tax, (ii) the income tax, (iii) the property tax, (iv) the land tax
Canada–Armenia Tax Convention Act, 2004 — C-0.7
(hereinafter referred to as “Armenian tax”).
Canada–Armenia Tax Convention Act, 2004 — C-0.7 4
4 The Convention shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes.