GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Canada–Greece Tax Convention Act, 2010 — C-5.9 4
4 The provisions of paragraphs 1 and 2 shall not apply to income derived from activities performed in a Contracting State by a resident of the other Contracting State which is a non-profit organization or an entertainer or sportsperson, if the visit to the first-mentioned Contracting State is substantially supported by public funds and the activities are not performed for the purpose of profit.
Canada–Greece Tax Convention Act, 2010 — C-5.9 1
1 Pensions and annuities arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
Canada–Greece Tax Convention Act, 2010 — C-5.9 2
2 Pensions arising in a Contracting State and paid to a resident of the other Contracting State may also be taxed in the State in which they arise and according to the law of that State, but of the total amount of such pensions paid in any calendar year to a resident of the other Contracting State, the first-mentioned Contracting State shall exempt from tax fifteen thousand Canadian dollars or the equivalent amount in euros. However, in the case of periodic pension payments, the tax so charged shall not exceed the lesser of: (a) 15 per cent of the gross amount of the total of such payments in the calendar year concerned in excess of fifteen thousand Canadian dollars or its equivalent in euros; and (b) the rate determined by reference to the amount of tax that the recipient of the payment would otherwise be required to pay for the year on the total amount of the periodic pension payments received by the individual in the year, if the individual were a resident of the Contracting State in which the payment arises. The competent authorities of the Contracting States may, if necessary, agree to modify the above-mentioned amount as a result of monetary or economic developments.
Canada–Greece Tax Convention Act, 2010 — C-5.9 (a)
(a) 15 per cent of the gross amount of the total of such payments in the calendar year concerned in excess of fifteen thousand Canadian dollars or its equivalent in euros; and
Canada–Greece Tax Convention Act, 2010 — C-5.9 (b)
(b) the rate determined by reference to the amount of tax that the recipient of the payment would otherwise be required to pay for the year on the total amount of the periodic pension payments received by the individual in the year, if the individual were a resident of the Contracting State in which the payment arises.
Canada–Greece Tax Convention Act, 2010 — C-5.9
The competent authorities of the Contracting States may, if necessary, agree to modify the above-mentioned amount as a result of monetary or economic developments.
Canada–Greece Tax Convention Act, 2010 — C-5.9 3
3 Annuities arising in a Contracting State and paid to a resident of the other Contracting State may also be taxed in the State in which they arise, and according to the law of that State; but the tax so charged shall not exceed 15 per cent of the portion thereof that is subject to tax in that State. However, this limitation does not apply to lump-sum payments arising on the surrender, cancellation, redemption, sale or other alienation of an annuity, or to payments of any kind under an annuity contract the cost of which was deductible, in whole or in part, in computing the income of any person who acquired the contract.
Canada–Greece Tax Convention Act, 2010 — C-5.9 4
4 Notwithstanding anything in this Convention: (a) war pensions and allowances (including pensions and allowances paid to war veterans or paid as a consequence of damages or injuries suffered as a consequence of a war) arising in a Contracting State and paid to a resident of the other Contracting State shall be exempt from tax in that other State to the extent that they would be exempt from tax if received by a resident of the first-mentioned State; (b) alimony and other similar payments arising in a Contracting State and paid to a resident of the other Contracting State who is subject to tax therein in respect thereof shall be taxable only in that other State but the amount taxable in that other State shall not exceed the amount that would be taxable in the first-mentioned State if the recipient were a resident thereof.
Canada–Greece Tax Convention Act, 2010 — C-5.9 (a)
(a) war pensions and allowances (including pensions and allowances paid to war veterans or paid as a consequence of damages or injuries suffered as a consequence of a war) arising in a Contracting State and paid to a resident of the other Contracting State shall be exempt from tax in that other State to the extent that they would be exempt from tax if received by a resident of the first-mentioned State;
Canada–Greece Tax Convention Act, 2010 — C-5.9 (b)
(b) alimony and other similar payments arising in a Contracting State and paid to a resident of the other Contracting State who is subject to tax therein in respect thereof shall be taxable only in that other State but the amount taxable in that other State shall not exceed the amount that would be taxable in the first-mentioned State if the recipient were a resident thereof.
Canada–Greece Tax Convention Act, 2010 — C-5.9 1. (a)
1. (a) Salaries, wages and other similar remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State.
Canada–Greece Tax Convention Act, 2010 — C-5.9 (b)
(b) However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who: (i) is a national of that State, or (ii) did not become a resident of that State solely for the purpose of rendering the services.
Canada–Greece Tax Convention Act, 2010 — C-5.9 (ii)
(ii) did not become a resident of that State solely for the purpose of rendering the services.
Canada–Greece Tax Convention Act, 2010 — C-5.9 2
2 The provisions of Articles 15, 16 and 17, as the case may be, shall apply instead of the provisions of paragraph 1 in the case of salaries, wages and other similar remuneration in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof.
Canada–Greece Tax Convention Act, 2010 — C-5.9
Payments which a student or business apprentice who is, or was immediately before visiting a Contracting State, a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of that individual’s education or training receives for the purpose of that individual’s maintenance, education or training shall not be taxed in that State, if such payments arise from sources outside that State.
Canada–Greece Tax Convention Act, 2010 — C-5.9 1
1 Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State.
Canada–Greece Tax Convention Act, 2010 — C-5.9 2
2 The provisions of paragraph 1 shall not apply to income, other than income from immovable property, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply.
Canada–Greece Tax Convention Act, 2010 — C-5.9 3
3 Notwithstanding the provisions of paragraphs 1 and 2, items of income of a resident of a Contracting State not dealt with in the foregoing Articles of the Convention and arising in the other Contracting State may also be taxed in that other State, and according to the law of that State. Where such income is income from a trust, other than a trust to which contributions were deductible, the tax so charged shall, if the income is taxable in the Contracting State in which the beneficial owner is a resident, not exceed 15 per cent of the gross amount of the income.
Canada–Greece Tax Convention Act, 2010 — C-5.9 1
1 Capital represented by immovable property owned by a resident of a Contracting State and situated in the other Contracting State may be taxed in that other State.
Canada–Greece Tax Convention Act, 2010 — C-5.9 2
2 Capital represented by movable property forming part of the business property of a permanent establishment that an enterprise of a Contracting State has in the other Contracting State, or by 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 independent personal services, may be taxed in that other State.
Canada–Greece Tax Convention Act, 2010 — C-5.9 3
3 Capital represented by ships or aircraft operated in international traffic and by movable property pertaining to the operation of such ships or aircraft, shall be taxable only in the Contracting State in which the profits from the operation of such ships or aircraft are taxable according to the provisions of Article 8.
Canada–Greece Tax Convention Act, 2010 — C-5.9 4
4 All other elements of capital of a resident of a Contracting State shall be taxable only in that State.
Canada–Greece Tax Convention Act, 2010 — C-5.9 1
1 In the case of the Hellenic Republic, double taxation shall be avoided as follows: (a) where a resident of the Hellenic Republic derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in Canada, the Hellenic Republic shall allow: (i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Canada, (ii) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in Canada; (b) subject to the existing provisions of the law of the Hellenic Republic regarding the allowance as a credit against Hellenic Republic tax of tax payable in a territory outside the Hellenic Republic and to any subsequent modification of those provisions — which shall not affect the general principle hereof — where a company which is a resident of Canada pays a dividend to a company which is a resident of the Hellenic Republic and which controls directly or indirectly at least 10 per cent of the voting power in the first-mentioned company, the credit shall take into account the tax payable in Canada by that first-mentioned company in respect of the profits out of which such dividend is paid; and (c) such deduction in either case shall not, however, exceed that part of the income tax or capital tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital that may be taxed in Canada.
Canada–Greece Tax Convention Act, 2010 — C-5.9 (a)
(a) where a resident of the Hellenic Republic derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in Canada, the Hellenic Republic shall allow: (i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Canada, (ii) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in Canada;
Canada–Greece Tax Convention Act, 2010 — C-5.9 (i)
(i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Canada,
Canada–Greece Tax Convention Act, 2010 — C-5.9 (ii)
(ii) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in Canada;
Canada–Greece Tax Convention Act, 2010 — C-5.9 (b)
(b) subject to the existing provisions of the law of the Hellenic Republic regarding the allowance as a credit against Hellenic Republic tax of tax payable in a territory outside the Hellenic Republic and to any subsequent modification of those provisions — which shall not affect the general principle hereof — where a company which is a resident of Canada pays a dividend to a company which is a resident of the Hellenic Republic and which controls directly or indirectly at least 10 per cent of the voting power in the first-mentioned company, the credit shall take into account the tax payable in Canada by that first-mentioned company in respect of the profits out of which such dividend is paid; and
Canada–Greece Tax Convention Act, 2010 — C-5.9 (c)
(c) such deduction in either case shall not, however, exceed that part of the income tax or capital tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital that may be taxed in Canada.
Canada–Greece Tax Convention Act, 2010 — C-5.9 2
2 In the case of Canada, double taxation shall be avoided as follows: (a) subject to the existing provisions of the law of Canada regarding the deduction from tax payable in Canada of tax paid in a territory outside Canada and to any subsequent modification of those provisions — which shall not affect the general principle hereof — and unless a greater deduction or relief is provided under the laws of Canada, tax payable in the Hellenic Republic on profits, income or gains arising in the Hellenic Republic shall be deducted from any Canadian tax payable in respect of such profits, income or gains; (b) subject to the existing provisions of the law of Canada regarding the allowance as a credit against Canadian tax of tax payable in a territory outside Canada and to any subsequent modification of those provisions — which shall not affect the general principle hereof — where a company which is a resident of the Hellenic Republic pays a dividend to a company which is a resident of Canada and which controls directly or indirectly at least 10 per cent of the voting power in the first-mentioned company, the credit shall take into account the tax payable in the Hellenic Republic by that first-mentioned company in respect of the profits out of which such dividend is paid; and (c) where, in accordance with any provision of the Convention, income derived or capital owned by a resident of Canada is exempt from tax in Canada, Canada may nevertheless, in calculating the amount of tax on other income or capital, take into account the exempted income or capital.
Canada–Greece Tax Convention Act, 2010 — C-5.9 (a)
(a) subject to the existing provisions of the law of Canada regarding the deduction from tax payable in Canada of tax paid in a territory outside Canada and to any subsequent modification of those provisions — which shall not affect the general principle hereof — and unless a greater deduction or relief is provided under the laws of Canada, tax payable in the Hellenic Republic on profits, income or gains arising in the Hellenic Republic shall be deducted from any Canadian tax payable in respect of such profits, income or gains;
Canada–Greece Tax Convention Act, 2010 — C-5.9 (b)
(b) subject to the existing provisions of the law of Canada regarding the allowance as a credit against Canadian tax of tax payable in a territory outside Canada and to any subsequent modification of those provisions — which shall not affect the general principle hereof — where a company which is a resident of the Hellenic Republic pays a dividend to a company which is a resident of Canada and which controls directly or indirectly at least 10 per cent of the voting power in the first-mentioned company, the credit shall take into account the tax payable in the Hellenic Republic by that first-mentioned company in respect of the profits out of which such dividend is paid; and
Canada–Greece Tax Convention Act, 2010 — C-5.9 (c)
(c) where, in accordance with any provision of the Convention, income derived or capital owned by a resident of Canada is exempt from tax in Canada, Canada may nevertheless, in calculating the amount of tax on other income or capital, take into account the exempted income or capital.
Canada–Greece Tax Convention Act, 2010 — C-5.9 3
3 For the purposes of this Article, profits, income or gains of a resident of a Contracting State that may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State.
Canada–Greece Tax Convention Act, 2010 — C-5.9 1
1 Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith that is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances, in particular with respect to residence, are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, also apply to individuals who are not residents of one or both of the Contracting States.
Canada–Greece Tax Convention Act, 2010 — C-5.9 2
2 The taxation on a permanent establishment that 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. This provision shall not 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 that it grants to its own residents.
Canada–Greece Tax Convention Act, 2010 — C-5.9 3
3 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 that is other or more burdensome than the taxation and connected requirements to which other similar enterprises that are residents 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–Greece Tax Convention Act, 2010 — C-5.9 4
4 In this Article, the term taxation means taxes that are the subject of this Convention.
Canada–Greece Tax Convention Act, 2010 — C-5.9 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, present the case in writing to the competent authority of the Contracting State of which that person is a resident or, if the case comes under paragraph 1 of Article 24, to that of the Contracting State of which that person is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Canada–Greece Tax Convention Act, 2010 — C-5.9 2
2 The competent authority 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States.
Canada–Greece Tax Convention Act, 2010 — C-5.9 3
3 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. They may also consult together for the elimination of double taxation in cases not provided for in the Convention.
Canada–Greece Tax Convention Act, 2010 — C-5.9 4
4 The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs.
Canada–Greece Tax Convention Act, 2010 — C-5.9 5
5 If any difficulty or doubt arising as to the interpretation or application of the Convention cannot be resolved by the competent authorities it may, if both competent authorities agree, be submitted for arbitration. The procedures for arbitration shall be established between the competent authorities.
Canada–Greece Tax Convention Act, 2010 — C-5.9 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 the Convention. The exchange of information is not restricted by Articles 1 and 2.
Canada–Greece Tax Convention Act, 2010 — C-5.9 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 in respect of, or the determination of appeals in relation to taxes, 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.
Canada–Greece Tax Convention Act, 2010 — C-5.9 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 that is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; or (c) to supply information that 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–Greece Tax Convention Act, 2010 — C-5.9 (a)
(a) to carry out administrative measures at variance with the laws and the administrative practice of that or of the other Contracting State;
Canada–Greece Tax Convention Act, 2010 — C-5.9 (b)
(b) to supply information that is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; or
Canada–Greece Tax Convention Act, 2010 — C-5.9 (c)
(c) to supply information that 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–Greece Tax Convention Act, 2010 — C-5.9 4
4 If information is requested by a Contracting State in accordance with this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though the other State does not need such information for its own tax purposes. The obligation contained in the preceding sentence is subject to the limitations of paragraph 3 but in no case shall such limitations be construed to permit a Contracting State to decline to supply information solely because it has no domestic interest in such information.
Canada–Greece Tax Convention Act, 2010 — C-5.9 5
5 In no case shall the provisions of paragraph 3 be construed to permit a Contracting State to decline to supply information solely because the information is held by a bank, other financial institution, nominee or person acting in an agency or fiduciary capacity or because the information relates to ownership interests in a person.
Canada–Greece Tax Convention Act, 2010 — C-5.9 1
1 Nothing in this Convention shall affect the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or under the provisions of special agreements.