GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — “3
“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 may be taxed in that State.”
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — 3
3 Paragraph 5 of Article 15 of the Convention shall be deleted.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains
Paragraph 3 of Article 18 of the Convention shall be deleted.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — “2
Paragraph 2 of Article 21 of the Convention shall be deleted and replaced by the following: “2 Subject to the provisions of the law of the United Kingdom regarding the allowance as a credit against United Kingdom tax of tax payable in a territory outside the United Kingdom or, as the case may be, regarding the exemption from United Kingdom tax of a dividend arising in a territory outside the United Kingdom or of the profits of a permanent establishment situated in a territory outside the United Kingdom (which shall not affect the general principle of this Article): (a) Canadian tax payable under the laws of Canada and in accordance with this Convention, whether directly or by deduction, on profits, income or chargeable gains from sources within Canada (excluding in the case of a dividend tax payable in respect of the profits out of which the dividend is paid) shall be allowed as a credit against any United Kingdom tax computed by reference to the same profits, income or chargeable gains by reference to which the Canadian tax is computed; (b) a dividend which is paid by a company which is a resident of Canada to a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax, when the exemption is applicable and the conditions for exemption under the law of the United Kingdom are met; (c) the profits of a permanent establishment in Canada of a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax when the exemption is applicable and the conditions for exemption under the law of the United Kingdom are met; (d) in the case of a dividend not exempted from tax under subparagraph (b) which is paid by a company which is a resident of Canada to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph (a) shall also take into account the Canadian tax payable by the company in respect of its profits out of which such dividend is paid.”
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — “2
“2 Subject to the provisions of the law of the United Kingdom regarding the allowance as a credit against United Kingdom tax of tax payable in a territory outside the United Kingdom or, as the case may be, regarding the exemption from United Kingdom tax of a dividend arising in a territory outside the United Kingdom or of the profits of a permanent establishment situated in a territory outside the United Kingdom (which shall not affect the general principle of this Article): (a) Canadian tax payable under the laws of Canada and in accordance with this Convention, whether directly or by deduction, on profits, income or chargeable gains from sources within Canada (excluding in the case of a dividend tax payable in respect of the profits out of which the dividend is paid) shall be allowed as a credit against any United Kingdom tax computed by reference to the same profits, income or chargeable gains by reference to which the Canadian tax is computed; (b) a dividend which is paid by a company which is a resident of Canada to a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax, when the exemption is applicable and the conditions for exemption under the law of the United Kingdom are met; (c) the profits of a permanent establishment in Canada of a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax when the exemption is applicable and the conditions for exemption under the law of the United Kingdom are met; (d) in the case of a dividend not exempted from tax under subparagraph (b) which is paid by a company which is a resident of Canada to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph (a) shall also take into account the Canadian tax payable by the company in respect of its profits out of which such dividend is paid.”
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — (a)
(a) Canadian tax payable under the laws of Canada and in accordance with this Convention, whether directly or by deduction, on profits, income or chargeable gains from sources within Canada (excluding in the case of a dividend tax payable in respect of the profits out of which the dividend is paid) shall be allowed as a credit against any United Kingdom tax computed by reference to the same profits, income or chargeable gains by reference to which the Canadian tax is computed;
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — (b)
(b) a dividend which is paid by a company which is a resident of Canada to a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax, when the exemption is applicable and the conditions for exemption under the law of the United Kingdom are met;
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — (c)
(c) the profits of a permanent establishment in Canada of a company which is a resident of the United Kingdom shall be exempted from United Kingdom tax when the exemption is applicable and the conditions for exemption under the law of the United Kingdom are met;
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — (d)
(d) in the case of a dividend not exempted from tax under subparagraph (b) which is paid by a company which is a resident of Canada to a company which is a resident of the United Kingdom and which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividend, the credit mentioned in subparagraph (a) shall also take into account the Canadian tax payable by the company in respect of its profits out of which such dividend is paid.”
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — “ARTICLE 23
issue relates to the residence of an individual), Article 5, Article 7, Article 9, Article 12 (but only insofar as Article 12 might apply in transactions involving related persons to which Article 9 might apply), Article 14, and any other Articles subsequently agreed by the Contracting States through an exchange of diplomatic notes.”
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — 1
1 Where a person considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with the provisions of this Convention, that person may, irrespective of the remedies provided by the domestic law of those States, address to the competent authority of the Contracting State of which that person is a resident an application in writing stating the grounds for claiming the revision of such taxation. To be admissible, the application must be submitted within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Convention.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — 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 this Convention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — 3
3 For the purposes of Articles 6, 7 and 14 of this Convention, a Contracting State shall not, after the expiry of the time limits provided in its domestic laws and, in any case, after eight years from the end of the taxable period to which the income concerned was attributed, make a primary adjustment to the income of a resident of one of the Contracting States where that income has been charged to tax in the other Contracting State in the hands of that resident. The foregoing shall not apply in the case of fraud or wilful default or where a person’s obligations have not been fulfilled owing to careless or deliberate behaviour.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — 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 this Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Convention.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — 5
5 The competent authorities of the Contracting States may communicate with each other directly for the purpose of applying this Convention.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — 6
6 Where, (a) under paragraph 1, a person has presented a case to the competent authority of a Contracting State on the basis that the actions of one or both of the Contracting States have resulted for that person in taxation not in accordance with the provisions of this Convention, and (b) the competent authorities are unable to reach an agreement to resolve that case pursuant to paragraph 2 within a period of three years from the date on which the information necessary to undertake substantive consideration for a mutual agreement has been received by both competent authorities or such other period from that date as is agreed by both competent authorities, any unresolved issues arising from the case shall be submitted to arbitration. The arbitration shall be conducted in the manner prescribed by the rules and procedures agreed upon by the Contracting States through an exchange of diplomatic notes. These unresolved issues shall not, however, be submitted to arbitration if a decision on these issues has already been rendered by a court or administrative tribunal of either State. Unless a person whose taxation is directly affected by the arbitration decision does not accept that decision, the decision shall be binding on both States and shall constitute a resolution by mutual agreement under this Article.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — (a)
(a) under paragraph 1, a person has presented a case to the competent authority of a Contracting State on the basis that the actions of one or both of the Contracting States have resulted for that person in taxation not in accordance with the provisions of this Convention, and
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — (b)
(b) the competent authorities are unable to reach an agreement to resolve that case pursuant to paragraph 2 within a period of three years from the date on which the information necessary to undertake substantive consideration for a mutual agreement has been received by both competent authorities or such other period from that date as is agreed by both competent authorities,
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains
any unresolved issues arising from the case shall be submitted to arbitration. The arbitration shall be conducted in the manner prescribed by the rules and procedures agreed upon by the Contracting States through an exchange of diplomatic notes. These unresolved issues shall not, however, be submitted to arbitration if a decision on these issues has already been rendered by a court or administrative tribunal of either State. Unless a person whose taxation is directly affected by the arbitration decision does not accept that decision, the decision shall be binding on both States and shall constitute a resolution by mutual agreement under this Article.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — 7
7 The provisions of paragraph 6 shall apply only with respect to issues arising under Article 4 (but only insofar as the issue relates to the residence of an individual), Article 5, Article 7, Article 9, Article 12 (but only insofar as Article 12 might apply in transactions involving related persons to which Article 9 might apply), Article 14, and any other Articles subsequently agreed by the Contracting States through an exchange of diplomatic notes.”
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — 1
1 The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Convention or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States, insofar as the taxation thereunder is not contrary to this Convention. The exchange of information is not restricted by Articles 1 and 2.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — 2
2 Any information received under paragraph 1 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) concerned with the assessment or collection of, the enforcement or prosecution in respect of, the determination of appeals in relation to taxes of every kind and description imposed by or on behalf of the Contracting States or of their political subdivisions, or the oversight of the above. 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. Notwithstanding the foregoing, information received by a Contracting State may be used for other purposes when such information may be used for such other purposes under the laws of both States and the competent authority of the supplying State authorises such use.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — 3
3 In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting State the obligation (a) to carry out administrative measures at variance with the laws and 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 ).