GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Proclamation Giving Notice that 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 April 21, 1998 — (a)
Now Know You that We, by and with the advice of Our Privy Council for Canada, do by this Our Proclamation give notice that (a) the Convention Between Canada and Switzerland for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital , set out in Schedule VI to 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 , ceased to be effective pursuant to paragraph 3 of Article 28 of 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 , annexed hereto, in respect of taxes to which the latter Convention applies in accordance with the provisions of paragraph 2 of that Article, and (b) 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 , annexed hereto, came into force upon the exchange of instruments of its ratification, on April 21, 1998.
Proclamation Giving Notice that 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 April 21, 1998 — (a)
(a) the Convention Between Canada and Switzerland for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital , set out in Schedule VI to 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 , ceased to be effective pursuant to paragraph 3 of Article 28 of 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 , annexed hereto, in respect of taxes to which the latter Convention applies in accordance with the provisions of paragraph 2 of that Article, and
Proclamation Giving Notice that 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 April 21, 1998 — (b)
(b) 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 , annexed hereto, came into force upon the exchange of instruments of its ratification, on April 21, 1998.
Proclamation Giving Notice that 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 April 21, 1998 — Proclamation Giving Notice that 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 April 21, 1998
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 Swiss Federal Council for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital Came into Force on April 21, 1998 — Proclamation Giving Notice that 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 April 21, 1998
In Testimony Whereof, We have caused these Our Letters to be made Patent and the Great Seal of Canada to be hereunto affixed. Witness: Our Right Trusty and Well-beloved Roméo A. LeBlanc, a Member of Our Privy Council for Canada, Chancellor and Principal Companion of Our Order of Canada, Chancellor and Commander of Our Order of Military Merit, Governor General and Commander-in-Chief of Canada.
Proclamation Giving Notice that 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 April 21, 1998 — Proclamation Giving Notice that 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 April 21, 1998
At Our Government House, in Our City of Ottawa, this eighteenth day of September in the year of Our Lord one thousand nine hundred and ninety-eight and in the forty-seventh year of Our Reign.
Proclamation Giving Notice that 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 April 21, 1998 — Proclamation Giving Notice that 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 April 21, 1998
The Government of Canada and the Swiss Federal Council, desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income and on capital, have agreed as follows:
Proclamation Giving Notice that 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 April 21, 1998 — Proclamation Giving Notice that 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 April 21, 1998
This Convention shall apply to persons who are residents of one or both of the Contracting States.
Proclamation Giving Notice that 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 April 21, 1998 — 1
1 This Convention shall apply to taxes on income and on capital imposed on behalf of each Contracting State, irrespective of the manner in which they are levied.
Proclamation Giving Notice that 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 April 21, 1998 — 2
2 There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, as well as taxes on capital appreciation.
Proclamation Giving Notice that 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 April 21, 1998 — 3
3 The existing taxes to which the Convention shall apply are, in particular: (a) in the case of Canada: the taxes imposed by the Government of Canada under the Income Tax Act, (hereinafter referred to as “Canadian tax”); (b) in the case of Switzerland: the federal, cantonal and communal taxes (i) on income (total income, earned income, income from capital, industrial and commercial profits, capital gains, and other items of income); and (ii) on capital (total property, movable and immovable property, business assets, paid-up capital and reserves, and other items of capital); (hereinafter referred to as “Swiss tax”).
Proclamation Giving Notice that 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 April 21, 1998 — (a)
(a) in the case of Canada: the taxes imposed by the Government of Canada under the Income Tax Act, (hereinafter referred to as “Canadian tax”);
Proclamation Giving Notice that 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 April 21, 1998 — (b)
(b) in the case of Switzerland: the federal, cantonal and communal taxes (i) on income (total income, earned income, income from capital, industrial and commercial profits, capital gains, and other items of income); and (ii) on capital (total property, movable and immovable property, business assets, paid-up capital and reserves, and other items of capital); (hereinafter referred to as “Swiss tax”).
Proclamation Giving Notice that 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 April 21, 1998 — (i)
(i) on income (total income, earned income, income from capital, industrial and commercial profits, capital gains, and other items of income); and
Proclamation Giving Notice that 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 April 21, 1998 — (ii)
(ii) on capital (total property, movable and immovable property, business assets, paid-up capital and reserves, and other items of capital);
Proclamation Giving Notice that 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 April 21, 1998 — Proclamation Giving Notice that 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 April 21, 1998
(hereinafter referred to as “Swiss tax”).
Proclamation Giving Notice that 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 April 21, 1998 — 4
4 The Convention shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes which have been made in their respective taxation laws.
Proclamation Giving Notice that 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 April 21, 1998 — 1
1 In this Convention, unless the context otherwise requires: (a) (i) the term “Canada” used in a geographical sense, means the territory of Canada, including: (A) any area beyond the territorial seas of Canada which, in accordance with international law and the laws of Canada, is an area within which Canada may exercise rights with respect to the seabed and subsoil and their natural resources; (B) the seas and airspace above every area referred to in clause (A) in respect of any activity carried on in connection with the exploration for or the exploitation of the natural resources referred to therein; (ii) the term “Switzerland” means the Swiss Confederation; (b) the terms “a Contracting State” and “the other Contracting State” mean, as the context requires, Canada or Switzerland; (c) the term “person” includes an individual, an estate, a trust, a company, a partnership and any other body of persons; (d) the term “company” means any body corporate or any entity which is treated as a body corporate for tax purposes; (e) the terms “enterprise of a Contracting State” and “enterprise of the other Contracting State” mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State; (f) the term “competent authority” means: (i) in the case of Canada, the Minister of National Revenue or his authorized representative; (ii) in the case of Switzerland, the Director of the Federal Tax Administration or his authorized representative; (g) the term “tax” means Canadian tax or Swiss tax, as the context requires; (h) the term “national” means: (i) any individual possessing the nationality of a Contracting State; (ii) any legal person, partnership and association deriving its status as such from the laws in force in a Contracting State.
Proclamation Giving Notice that 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 April 21, 1998 — (i)
(i) the term “Canada” used in a geographical sense, means the territory of Canada, including: (A) any area beyond the territorial seas of Canada which, in accordance with international law and the laws of Canada, is an area within which Canada may exercise rights with respect to the seabed and subsoil and their natural resources; (B) the seas and airspace above every area referred to in clause (A) in respect of any activity carried on in connection with the exploration for or the exploitation of the natural resources referred to therein;
Proclamation Giving Notice that 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 April 21, 1998 — (A)
(A) any area beyond the territorial seas of Canada which, in accordance with international law and the laws of Canada, is an area within which Canada may exercise rights with respect to the seabed and subsoil and their natural resources;
Proclamation Giving Notice that 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 April 21, 1998 — (B)
(B) the seas and airspace above every area referred to in clause (A) in respect of any activity carried on in connection with the exploration for or the exploitation of the natural resources referred to therein;
Proclamation Giving Notice that 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 April 21, 1998 — (ii)
(ii) the term “Switzerland” means the Swiss Confederation;
Proclamation Giving Notice that 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 April 21, 1998 — (b)
(b) the terms “a Contracting State” and “the other Contracting State” mean, as the context requires, Canada or Switzerland;
Proclamation Giving Notice that 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 April 21, 1998 — (c)
(c) the term “person” includes an individual, an estate, a trust, a company, a partnership and any other body of persons;
Proclamation Giving Notice that 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 April 21, 1998 — (d)
(d) the term “company” means any body corporate or any entity which is treated as a body corporate for tax purposes;
Proclamation Giving Notice that 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 April 21, 1998 — (e)
(e) the terms “enterprise of a Contracting State” and “enterprise of the other Contracting State” mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;
Proclamation Giving Notice that 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 April 21, 1998 — (f)
(f) the term “competent authority” means: (i) in the case of Canada, the Minister of National Revenue or his authorized representative; (ii) in the case of Switzerland, the Director of the Federal Tax Administration or his authorized representative;
Proclamation Giving Notice that 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 April 21, 1998 — (i)
(i) in the case of Canada, the Minister of National Revenue or his authorized representative;
Proclamation Giving Notice that 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 April 21, 1998 — (ii)
(ii) in the case of Switzerland, the Director of the Federal Tax Administration or his authorized representative;
Proclamation Giving Notice that 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 April 21, 1998 — (g)
(g) the term “tax” means Canadian tax or Swiss tax, as the context requires;
Proclamation Giving Notice that 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 April 21, 1998 — (h)
(h) the term “national” means: (i) any individual possessing the nationality of a Contracting State; (ii) any legal person, partnership and association deriving its status as such from the laws in force in a Contracting State.
Proclamation Giving Notice that 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 April 21, 1998 — (i)
(i) any individual possessing the nationality of a Contracting State;
Proclamation Giving Notice that 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 April 21, 1998 — (ii)
(ii) any legal person, partnership and association deriving its status as such from the laws in force in a Contracting State.
Proclamation Giving Notice that 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 April 21, 1998 — 2
2 As regards the application of the Convention by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which the Convention applies.
Proclamation Giving Notice that 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 April 21, 1998 — 1
1 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.
Proclamation Giving Notice that 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 April 21, 1998 — 2
2 Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident of the State of which he is a national; (d) if he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Proclamation Giving Notice that 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 April 21, 1998 — (a)
(a) he shall be deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (centre of vital interests);
Proclamation Giving Notice that 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 April 21, 1998 — (b)
(b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode;
Proclamation Giving Notice that 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 April 21, 1998 — (c)
(c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident of the State of which he is a national;
Proclamation Giving Notice that 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 April 21, 1998 — (d)
(d) if he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Proclamation Giving Notice that 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 April 21, 1998 — 3
3 Where by reason of the provisions of paragraph 1 a company is a resident of both Contracting States, then its status shall be determined as follows: (a) it shall be deemed to be a resident of the State of which it is a national; (b) if it is a national of neither of the States, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Proclamation Giving Notice that 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 April 21, 1998 — (a)
(a) it shall be deemed to be a resident of the State of which it is a national;