GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998
However, the term does not include a permanent establishment within the meaning of subparagraph c. of paragraph (3) of Article 2 of the Indonesian Law Number 7 of 1983 concerning income tax as amended.”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — 1
1 Subparagraph 2(h) of Article 5 (Permanent Establishment) of the Convention shall be deleted and replaced by the following: “(h) a building site, a construction, installation or assembly project or supervisory activities in connection therewith, where such site, project or activity continues for a period of more than 120 days;”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — “(h)
“(h) a building site, a construction, installation or assembly project or supervisory activities in connection therewith, where such site, project or activity continues for a period of more than 120 days;”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — 2
2 Subparagraph 2(i) of Article 5 (Permanent Establishment) of the Convention shall be deleted and replaced by the following: “(i) the furnishing of services, including consultancy services, by an enterprise through an employee or other person (other than an agent of an independent status within the meaning of paragraph 6) where the activities continue within a Contracting State for more than 120 days within any twelve month period.”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — “(i)
“(i) the furnishing of services, including consultancy services, by an enterprise through an employee or other person (other than an agent of an independent status within the meaning of paragraph 6) where the activities continue within a Contracting State for more than 120 days within any twelve month period.”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — 1
1 Paragraph 2 of Article 8 (Shipping and Air Transport) of the Convention shall be deleted and replaced by the following: 2 Notwithstanding the provisions of paragraph 1 and of Article 7, profits derived from the operation of ships or aircraft used principally to transport passengers or goods between places in a Contracting State may be taxed in that State. 3 The provisions of paragraph 1 shall also apply to profits derived by an enterprise from its participation in a pool, a joint business or in an international operating agency but only to so much of the profits so derived as is allocable to the participant in an international joint venture in proportion to its share in the joint operation.”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — 2
2 Notwithstanding the provisions of paragraph 1 and of Article 7, profits derived from the operation of ships or aircraft used principally to transport passengers or goods between places in a Contracting State may be taxed in that State.
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — 3
3 The provisions of paragraph 1 shall also apply to profits derived by an enterprise from its participation in a pool, a joint business or in an international operating agency but only to so much of the profits so derived as is allocable to the participant in an international joint venture in proportion to its share in the joint operation.”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — “2
Paragraph 2 of Article 10 (Dividends) of the Convention shall be deleted and replaced by the following: “2 However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that State, but if the beneficial owner of the dividends is a resident of the other State, the tax so charged shall not exceed: (a) 10 per cent of the gross amount of the dividends if the beneficial owner is a company which holds directly at least 25 per cent of the capital of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. The provisions of this paragraph shall not affect the taxation of the company on the profits out of which the dividends are paid.”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — “2
“2 However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that State, but if the beneficial owner of the dividends is a resident of the other State, the tax so charged shall not exceed: (a) 10 per cent of the gross amount of the dividends if the beneficial owner is a company which holds directly at least 25 per cent of the capital of the company paying the dividends; (b) 15 per cent of the gross amount of the dividends in all other cases. The provisions of this paragraph shall not affect the taxation of the company on the profits out of which the dividends are paid.”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — (a)
(a) 10 per cent of the gross amount of the dividends if the beneficial owner is a company which holds directly at least 25 per cent of the capital of the company paying the dividends;
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — (b)
(b) 15 per cent of the gross amount of the dividends in all other cases.
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998
The provisions of this paragraph shall not affect the taxation of the company on the profits out of which the dividends are paid.”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — “2
Paragraph 2 of Article 11 (Interest) of the Convention shall be deleted and replaced by the following: “2 However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the beneficial owner of the interest is a resident of the other State, the tax so charged shall not exceed 10 per cent of the gross amount of the interest.”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — “2
“2 However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the beneficial owner of the interest is a resident of the other State, the tax so charged shall not exceed 10 per cent of the gross amount of the interest.”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — 1
1 Paragraph 2 of Article 12 (Royalties) of the Convention shall be deleted and replaced by the following: “2 However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties.”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — “2
“2 However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other State, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties.”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — 2
2 The following sentence shall be added at the end of paragraph 3 of Article 12 (Royalties) of the Convention: “However, the term does not include payments for the furnishing of technical services (such as studies or surveys of a scientific, geological or technical nature, engineering contracts including blueprints related thereto, and consultancy and supervisory services).”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998
“However, the term does not include payments for the furnishing of technical services (such as studies or surveys of a scientific, geological or technical nature, engineering contracts including blueprints related thereto, and consultancy and supervisory services).”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — “2
Paragraphs 2 and 3 of Article 13 (Gains from the Alienation of Property) shall be deleted and replaced by the following: “2 Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing professional services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base may be taxed in that other State. However, gains from the alienation of ships or aircraft operated by an enterprise of a Contracting State in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that Contracting State. 3 Gains derived by a resident of a Contracting State from the alienation of (a) shares of a company which is a resident of the other State the value of which shares is derived principally from immovable property situated in that other State; or (b) an interest in a partnership, trust or estate, established under the law in the other State, the value of which is derived principally from immovable property situated in that other State, may be taxed in that other State. For the purposes of this paragraph, the term immovable property includes the shares of a company referred to in subparagraph (a) or an interest in a partnership, trust or estate referred to in subparagraph (b).”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — “2
“2 Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing professional services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base may be taxed in that other State. However, gains from the alienation of ships or aircraft operated by an enterprise of a Contracting State in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that Contracting State.
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — 3
3 Gains derived by a resident of a Contracting State from the alienation of (a) shares of a company which is a resident of the other State the value of which shares is derived principally from immovable property situated in that other State; or (b) an interest in a partnership, trust or estate, established under the law in the other State, the value of which is derived principally from immovable property situated in that other State, may be taxed in that other State. For the purposes of this paragraph, the term immovable property includes the shares of a company referred to in subparagraph (a) or an interest in a partnership, trust or estate referred to in subparagraph (b).”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — (a)
(a) shares of a company which is a resident of the other State the value of which shares is derived principally from immovable property situated in that other State; or
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — (b)
(b) an interest in a partnership, trust or estate, established under the law in the other State, the value of which is derived principally from immovable property situated in that other State,
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998
may be taxed in that other State. For the purposes of this paragraph, the term immovable property includes the shares of a company referred to in subparagraph (a) or an interest in a partnership, trust or estate referred to in subparagraph (b).”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — “1
Paragraph 1 of Article 14 (Professional Services) of the Convention shall be deleted and replaced by the following: “1 Income derived by an individual who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State unless he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities or he is present in that other Contracting State for a period or periods exceeding in the aggregate 120 days in any twelve month period. If he has or had such a fixed base or remains in that other Contracting State for the aforesaid period or periods, the income may be taxed in that other Contracting State but only so much of it as is attributable to that fixed base or is derived in that other Contracting State during the aforesaid period or periods.”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — “1
“1 Income derived by an individual who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that Contracting State unless he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities or he is present in that other Contracting State for a period or periods exceeding in the aggregate 120 days in any twelve month period. If he has or had such a fixed base or remains in that other Contracting State for the aforesaid period or periods, the income may be taxed in that other Contracting State but only so much of it as is attributable to that fixed base or is derived in that other Contracting State during the aforesaid period or periods.”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — “2
Paragraphs 2 and 3 of Article 15 (Dependent Personal Services) of the Convention shall be deleted and replaced by the following: “2 Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 120 days within any twelve month period, and either: (a) the remuneration earned in the other Contracting State within the twelve month period does not exceed five thousand Canadian dollars ($5,000) or its equivalent in rupiah, or such other amount as is specified and agreed in letters exchanged between the competent authorities of the Contracting States; or (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and such remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State. 3 Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State, shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.”
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — “2
“2 Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 120 days within any twelve month period, and either: (a) the remuneration earned in the other Contracting State within the twelve month period does not exceed five thousand Canadian dollars ($5,000) or its equivalent in rupiah, or such other amount as is specified and agreed in letters exchanged between the competent authorities of the Contracting States; or (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and such remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
Proclamation giving notice that the Protocol Amending the Convention between Canada and the Republic of Indonesia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital came into force on December 31, 1998 — (a)
(a) the remuneration earned in the other Contracting State within the twelve month period does not exceed five thousand Canadian dollars ($5,000) or its equivalent in rupiah, or such other amount as is specified and agreed in letters exchanged between the competent authorities of the Contracting States; or