GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Proclamation Giving Notice that the Convention between the Government of Canada and the Government of the Italian Republic for the Avoidance of Double Taxation with Respect to Taxes on Income and the Prevention of Fiscal Evasion Came into Force on November 25, 2011 — (a)
Whereas by Order in Council P.C. 2012-230 of March 1, 2012, the Governor General in Council pursuant to section 9 of An Act to implement conventions between Canada and Spain, Canada and the Republic of Austria, Canada and Italy, Canada and the Republic of Korea, Canada and the Socialist Republic of Romania and Canada and the Republic of Indonesia and agreements between Canada and Malaysia, Canada and Jamaica and Canada and Barbados and a convention between Canada and the United Kingdom of Great Britain and Northern Ireland for the avoidance of double taxation with respect to income tax , has directed that a proclamation do issue giving notice (a) that the Convention between the Government of Canada and the Government of the Italian Republic for the Avoidance of Double Taxation With Respect to Taxes on Income and the Prevention of Fiscal Evasion signed at Ottawa on June 3, 2002, as set out in Schedule 7 to the Tax Conventions Implementation Act, 2002 , came into force on November 25, 2011; and (b) that the Convention between Canada and Italy for the Avoidance of Double Taxation With Respect to Taxes on Income and for the Prevention of Fiscal Evasion signed at Toronto on November 17, 1977 and the 1989 Protocol modifying that Convention cease to have effect in accordance with Article 28 of the Convention referred to in paragraph (a).
Proclamation Giving Notice that the Convention between the Government of Canada and the Government of the Italian Republic for the Avoidance of Double Taxation with Respect to Taxes on Income and the Prevention of Fiscal Evasion Came into Force on November 25, 2011 — (a)
(a) that the Convention between the Government of Canada and the Government of the Italian Republic for the Avoidance of Double Taxation With Respect to Taxes on Income and the Prevention of Fiscal Evasion signed at Ottawa on June 3, 2002, as set out in Schedule 7 to the Tax Conventions Implementation Act, 2002 , came into force on November 25, 2011; and
Proclamation Giving Notice that the Convention between the Government of Canada and the Government of the Italian Republic for the Avoidance of Double Taxation with Respect to Taxes on Income and the Prevention of Fiscal Evasion Came into Force on November 25, 2011 — (b)
(b) that the Convention between Canada and Italy for the Avoidance of Double Taxation With Respect to Taxes on Income and for the Prevention of Fiscal Evasion signed at Toronto on November 17, 1977 and the 1989 Protocol modifying that Convention cease to have effect in accordance with Article 28 of the Convention referred to in paragraph (a).
Proclamation Giving Notice that the Convention between the Government of Canada and the Government of the Italian Republic for the Avoidance of Double Taxation with Respect to Taxes on Income and the Prevention of Fiscal Evasion Came into Force on November 25, 2011 — (a)
Now know you that We, by and with the advice of Our Privy Council for Canada, do by this Our Proclamation give notice (a) that the Convention between the Government of Canada and the Government of the Italian Republic for the Avoidance of Double Taxation With Respect to Taxes on Income and the Prevention of Fiscal Evasion signed at Ottawa on June 3, 2002, as set out in Schedule 7 to the Tax Conventions Implementation Act, 2002 , came into force on November 25, 2011; and (b) that the Convention between Canada and Italy for the Avoidance of Double Taxation With Respect to Taxes on Income and for the Prevention of Fiscal Evasion signed at Toronto on November 17, 1977 and the 1989 Protocol modifying that Convention cease to have effect in accordance with Article 28 of the Convention referred to in paragraph (a).
Proclamation Giving Notice that the Convention between the Government of Canada and the Government of the Italian Republic for the Avoidance of Double Taxation with Respect to Taxes on Income and the Prevention of Fiscal Evasion Came into Force on November 25, 2011 — Proclamation Giving Notice that the Convention between the Government of Canada and the Government of the Italian Republic for the Avoidance of Double Taxation with Respect to Taxes on Income and the Prevention of Fiscal Evasion Came into Force on November 25, 2011
Of all which Our loving subjects and all others whom these Presents may concern are hereby required to take notice and to govern themselves accordingly.
Proclamation Giving Notice that the Convention between the Government of Canada and the Government of the Italian Republic for the Avoidance of Double Taxation with Respect to Taxes on Income and the Prevention of Fiscal Evasion Came into Force on November 25, 2011 — Proclamation Giving Notice that the Convention between the Government of Canada and the Government of the Italian Republic for the Avoidance of Double Taxation with Respect to Taxes on Income and the Prevention of Fiscal Evasion Came into Force on November 25, 2011
IN TESTIMONY WHEREOF, We have caused this Our Proclamation to be published and the Great Seal of Canada to be hereunto affixed. WITNESS: The Honourable Thomas A. Cromwell, a Puisne Judge of he Supreme Court of Canada and Deputy of Our Right Trusty and Well-beloved David Johnston, Chancellor and Principal Companion of Our Order of Canada, Chancellor and Commander of Our Order of Military Merit, Chancellor and Commander of Our Order of Merit of the Police Forces, Governor General and Commander-in-Chief of Canada.
Proclamation Giving Notice that the Convention between the Government of Canada and the Government of the Italian Republic for the Avoidance of Double Taxation with Respect to Taxes on Income and the Prevention of Fiscal Evasion Came into Force on November 25, 2011 — Proclamation Giving Notice that the Convention between the Government of Canada and the Government of the Italian Republic for the Avoidance of Double Taxation with Respect to Taxes on Income and the Prevention of Fiscal Evasion Came into Force on November 25, 2011
AT OTTAWA, this sixteenth day of March in the year of Our Lord two thousand and twelve and in the sixty-first year of Our Reign.
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011
ELIZABETH THE SECOND, by the Grace of God of the United Kingdom, Canada and Her other Realms and Territories QUEEN, Head of the Commonwealth, Defender of the Faith.
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011
To all to whom these Presents shall come or whom the same may in any way concern,
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011
Whereas by Order in Council P.C. 2012-231 of March 1, 2012, the Governor General in Council pursuant to subsection 19(4) of An Act to Implement Conventions between Canada and Morocco, Canada and Pakistan, Canada and Singapore, Canada and the Philippines, Canada and the Dominican Republic and Canada and Switzerland for the avoidance of double taxation with respect to income tax , directed that a proclamation do issue giving notice that the annexed supplementary convention, signed on October 22, 2010, entitled the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital , done at Berne on 5 May 1997, came into force on December 16, 2011 and applies in accordance with the provisions of Article XIII of that supplementary convention;
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011
Now know you that We, by and with the advice of Our Privy Council for Canada, do by this Our Proclamation give notice that the annexed supplementary convention, signed on October 22, 2010, entitled the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital , done at Berne on 5 May 1997, came into force on December 16, 2011 and applies in accordance with the provisions of Article XIII of that supplementary convention.
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011
Of all which Our loving subjects and all others whom these Presents may concern are hereby required to take notice and to govern themselves accordingly.
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011
IN TESTIMONY WHEREOF, We have caused this Our Proclamation to be published and the Great Seal of Canada to be hereunto affixed. WITNESS: The Honourable Thomas A. Cromwell, a Puisne Judge of the Supreme Court of Canada and Deputy of Our Right Trusty and Well-beloved David Johnston, Chancellor and Principal Companion of Our Order of Canada, Chancellor and Commander of Our Order of Military Merit, Chancellor and Commander of Our Order of Merit of the Police Forces, Governor General and Commander-in-Chief of Canada.
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011
AT OTTAWA, this sixteenth day of March in the year of Our Lord two thousand and twelve and in the sixty-first year of Our Reign.
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011
DESIRING to conclude a Protocol amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital , done at Berne on 5 May 1997 (the “Convention”),
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — “2
Paragraph 2 of Article 3 (General Definitions) of the Convention shall be deleted and replaced by the following: “2 As regards the application of the Convention by a Contracting State, at any time, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has at that time under the law of that State concerning the taxes to which the Convention applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.”
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — “2
“2 As regards the application of the Convention by a Contracting State, at any time, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has at that time under the law of that State concerning the taxes to which the Convention applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.”
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011
Paragraph 1 of Article 4 (Resident) of the Convention shall be amended by adding the following sentence at the end of the paragraph: “This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.” The amended paragraph shall therefore read as follows: “For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and in the case of Switzerland it includes a partnership created or organized under Swiss law. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.”
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011
“This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.”
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011
The amended paragraph shall therefore read as follows: “For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and in the case of Switzerland it includes a partnership created or organized under Swiss law. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.”
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011
“For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and in the case of Switzerland it includes a partnership created or organized under Swiss law. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.”
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011
Paragraph 3 of Article 9 (Associated Enterprises) of the Convention shall be amended by deleting the word “five” and replacing it with the word “six”. The amended paragraph shall therefore read as follows: “A Contracting State shall not change the income of an enterprise in the circumstances referred to in paragraph 1 after the expiry of the time limits provided in its domestic law and, in any case, after six years from the end of the year in which the income which would be subject to such change would have accrued to that enterprise. This paragraph shall not apply in the case of fraud or wilful default.”
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011
The amended paragraph shall therefore read as follows: “A Contracting State shall not change the income of an enterprise in the circumstances referred to in paragraph 1 after the expiry of the time limits provided in its domestic law and, in any case, after six years from the end of the year in which the income which would be subject to such change would have accrued to that enterprise. This paragraph shall not apply in the case of fraud or wilful default.”
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011
“A Contracting State shall not change the income of an enterprise in the circumstances referred to in paragraph 1 after the expiry of the time limits provided in its domestic law and, in any case, after six years from the end of the year in which the income which would be subject to such change would have accrued to that enterprise. This paragraph shall not apply in the case of fraud or wilful default.”
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — 1
1 Subparagraph (b) of paragraph 2 of Article 10 (Dividends) of the Convention shall be deleted and subparagraph (c) shall be renumbered as subparagraph (b).
Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 — 2
2 The following new paragraph 3 shall be added to Article 10 of the Convention: “3 Notwithstanding paragraph 2, dividends paid by a company which is a resident of a Contracting State shall be exempt from tax in that State if the dividends are paid to: (a) the Bank of Canada or the Swiss National Bank; or (b) a resident of the other Contracting State (i) that was constituted and is operated exclusively to administer or provide benefits under one or more pension or retirement plans; or (ii) that is operated exclusively to earn income for the benefit of one or more residents of that other Contracting State each of which satisfy clause (i), provided that: (iii) each pension or retirement plan provides benefits primarily to individuals who are residents of that other Contracting State; (iv) the dividends are not derived from carrying on a trade or a business or from a related person; and (v) the competent authorities of the Contracting States agree that each pension or retirement plan generally corresponds to a pension or retirement plan recognized for tax purposes in the first-mentioned State.”