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 — (a)
(a) to carry out administrative measures at variance with the laws and the administrative practice of that or of the other Contracting 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 — (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;
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) 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 ).
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 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 that other State may 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.
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 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 a fiduciary capacity or because the information relates to ownership interests in a person.
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 Authorised representatives of a Contracting State shall be permitted to enter the other Contracting State to interview individuals or examine a person’s books and records with their consent, in accordance with procedures mutually agreed upon by the 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 — 1
1 The Contracting States shall lend assistance to each other in the collection of revenue claims. This assistance is not restricted by Articles 1 and 2. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this Article, including agreement to ensure comparable levels of assistance.
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 term revenue claim as used in this Article means an amount owed in respect of taxes of every kind and description collected by or on behalf of the Contracting States, or on behalf of the political subdivisions of the Contracting States, insofar as the taxation thereunder is not contrary to this Convention or any other instrument to which the Contracting States are parties, as well as interest, administrative penalties and costs of collection or conservancy related to such amount.
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 When a revenue claim of a Contracting State is enforceable under the laws of that State and is owed by a person who, at that time, cannot, under the laws of that State, prevent its collection, that revenue claim shall, at the request of the competent authority of that State made in accordance with the mode of application referred to in paragraph 1, be accepted for purposes of collection by the competent authority of the other Contracting State. That revenue claim shall be collected by that other State in accordance with the provisions of its laws applicable to the enforcement and collection of its own taxes as if the revenue claim were a revenue claim of that other 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 — 4
4 Notwithstanding the provisions of paragraph 3, a revenue claim accepted by a Contracting State for purposes of paragraph 3 shall not, in that State, be accorded any priority applicable to a revenue claim under the laws of that State by reason of its nature as such. In addition, a revenue claim accepted by a Contracting State for the purposes of paragraph 3 shall not, in that State, have any priority applicable to that revenue claim under the laws of the other Contracting 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 — 5
5 Proceedings with respect to the existence, validity or the amount of a revenue claim of a Contracting State shall not be brought before the courts or administrative bodies of the other Contracting 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 — 6
6 Where, at any time after a request has been made by a Contracting State under paragraph 3 and before the other Contracting State has collected and remitted the relevant revenue claim to the first-mentioned State, the relevant revenue claim ceases to be a revenue claim of the firstmentioned State that is enforceable under the laws of that State and is owed by a person who, at that time, cannot, under the laws of that State, prevent its collection, the competent authority of the first-mentioned State shall promptly notify the competent authority of the other State of that fact and, at the option of the other State, the first-mentioned State shall either suspend or withdraw its request.
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 to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State; (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 carry out measures which would be contrary to public policy ( ordre public ); (c) to provide assistance if the other Contracting State has not pursued all reasonable measures of collection available under its laws or administrative practice; (d) to provide assistance in those cases where the administrative burden for that State is clearly disproportionate to the benefit to be derived by the other Contracting State; (e) to provide administrative assistance if and insofar as it considers the taxation in the other State to be contrary to generally accepted taxation principles.”
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) to carry out measures which would be contrary to public policy ( ordre public );
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) to provide assistance if the other Contracting State has not pursued all reasonable measures of collection available under its laws or administrative practice;
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) to provide assistance in those cases where the administrative burden for that State is clearly disproportionate to the benefit to be derived by the other Contracting 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 — (e)
(e) to provide administrative assistance if and insofar as it considers the taxation in the other State to be contrary to generally accepted taxation principles.”
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 Paragraph 3 of Article 27 of the Convention shall be deleted and replaced by the following: “3 Nothing in this Convention shall be construed as restricting the right of a Contracting State to tax a resident of that State on that resident’s share of any income or capital gains of a partnership, trust or controlled foreign affiliate in which that resident has an interest.”
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 Nothing in this Convention shall be construed as restricting the right of a Contracting State to tax a resident of that State on that resident’s share of any income or capital gains of a partnership, trust or controlled foreign affiliate in which that resident has an interest.”
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 Paragraph 5 of Article 27 of the Convention shall be deleted and paragraphs 6 and 7 shall be renumbered paragraphs 4 and 5 respectively.
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 Each Contracting State shall notify the other Contracting State, by diplomatic notes, of the completion of its internal procedures required to bring this Protocol into force. This Protocol shall enter into force on the date of the later of these notes and its provisions shall have effect: (a) in Canada: (i) 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 the date that this Protocol enters into force; and (ii) in respect of other Canadian tax, for taxation years beginning on or after the first day of January in the calendar year next following the date that this Protocol enters into force; (b) in the United Kingdom: (i) 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 the date that this Protocol enters into force; (ii) in respect of income tax and capital gains tax, for any year of assessment beginning on or after 6 th April next following the date that this Protocol enters into force; and (iii) in respect of corporation tax, for any financial year beginning on or after 1 st April next following the date that this Protocol enters into force.
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) in Canada: (i) 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 the date that this Protocol enters into force; and (ii) in respect of other Canadian tax, for taxation years beginning on or after the first day of January in the calendar year next following the date that this Protocol enters into force;
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 — (i)
(i) 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 the date that this Protocol enters into force; 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 — (ii)
(ii) in respect of other Canadian tax, for taxation years beginning on or after the first day of January in the calendar year next following the date that this Protocol enters into force;
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) in the United Kingdom: (i) 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 the date that this Protocol enters into force; (ii) in respect of income tax and capital gains tax, for any year of assessment beginning on or after 6 th April next following the date that this Protocol enters into force; and (iii) in respect of corporation tax, for any financial year beginning on or after 1 st April next following the date that this Protocol enters into force.
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 — (i)
(i) 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 the date that this Protocol enters into force;
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 — (ii)
(ii) in respect of income tax and capital gains tax, for any year of assessment beginning on or after 6 th April next following the date that this Protocol enters into force; 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 — (iii)
(iii) in respect of corporation tax, for any financial year beginning on or after 1 st April next following the date that this Protocol enters into force.
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 Notwithstanding the provisions of paragraph 1, the provisions of Article 23 (Mutual Agreement Procedure), Article 24 (Exchange of Information) and Article 24A (Assistance in the Collection of Taxes) of the Convention, introduced by Articles XII, XIII and XIV of this Protocol, shall have effect from the date of entry into force of this Protocol, without regard to the taxable period to which the matters relate. However, paragraphs 6 and 7 of Article 23 (Mutual Agreement Procedure) of the Convention introduced by Article XII of this Protocol shall have effect from the date specified through an exchange of diplomatic notes, and Article 24A (Assistance in the Collection of Taxes) introduced by Article XIV of this Protocol shall not apply to revenue claims in respect of taxation years ending more than five years before the date on which this Protocol enters into force.
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
IN WITNESS WHEREOF the undersigned, duly authorised thereto, have signed this Protocol.