GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (ii)
(ii) any legal person, partnership and association deriving its status as such from the laws in force in a Contracting State;
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (h)
(h) 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;
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (i)
(i) the term international traffic means any voyage of a ship or aircraft operated by an enterprise of a Contracting State to transport passengers or property except where the principal purpose of the voyage is to transport passengers or property between places within the other Contracting State.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 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 that it has at that time under the law of that State for the purposes of the taxes to which the Convention applies.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 1
1 For the purposes of this Convention, the term resident of a Contracting State means: (a) in the case of Canada, any person who, under the laws of that State, is liable to tax therein by reason of the person’s domicile, residence, place of management, place of incorporation or any other criterion of a similar nature but does not include any person who is liable to tax in that State in respect only of income from sources in that State; (b) in the case of the United Arab Emirates, (i) an individual who is a national of the United Arab Emirates, provided that the individual has a substantial presence, permanent home or habitual abode in the United Arab Emirates and that individual’s personal and economic relations are closer to the United Arab Emirates than to any other State; (ii) a company which is incorporated in the United Arab Emirates, provided such company can establish that: (A) all of the shares of the company are beneficially owned by residents of the United Arab Emirates; or (B) all or substantially all of the company’s income is derived by the company from the active conduct of a trade or business, other than an investment business, in the United Arab Emirates and all or substantially all of the value of the company’s property is attributable to property used in that trade or business.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (a)
(a) in the case of Canada, any person who, under the laws of that State, is liable to tax therein by reason of the person’s domicile, residence, place of management, place of incorporation or any other criterion of a similar nature but does not include any person who is liable to tax in that State in respect only of income from sources in that State;
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (b)
(b) in the case of the United Arab Emirates, (i) an individual who is a national of the United Arab Emirates, provided that the individual has a substantial presence, permanent home or habitual abode in the United Arab Emirates and that individual’s personal and economic relations are closer to the United Arab Emirates than to any other State; (ii) a company which is incorporated in the United Arab Emirates, provided such company can establish that: (A) all of the shares of the company are beneficially owned by residents of the United Arab Emirates; or (B) all or substantially all of the company’s income is derived by the company from the active conduct of a trade or business, other than an investment business, in the United Arab Emirates and all or substantially all of the value of the company’s property is attributable to property used in that trade or business.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (i)
(i) an individual who is a national of the United Arab Emirates, provided that the individual has a substantial presence, permanent home or habitual abode in the United Arab Emirates and that individual’s personal and economic relations are closer to the United Arab Emirates than to any other State;
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (ii)
(ii) a company which is incorporated in the United Arab Emirates, provided such company can establish that: (A) all of the shares of the company are beneficially owned by residents of the United Arab Emirates; or (B) all or substantially all of the company’s income is derived by the company from the active conduct of a trade or business, other than an investment business, in the United Arab Emirates and all or substantially all of the value of the company’s property is attributable to property used in that trade or business.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (A)
(A) all of the shares of the company are beneficially owned by residents of the United Arab Emirates; or
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (B)
(B) all or substantially all of the company’s income is derived by the company from the active conduct of a trade or business, other than an investment business, in the United Arab Emirates and all or substantially all of the value of the company’s property is attributable to property used in that trade or business.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 2
2 For the purposes of paragraph 1, the term resident of a Contracting State shall include: (a) the Government of that Contracting State or a political subdivision or local Government or local authority thereof; and (b) any corporation, Central Bank, Abu Dhabi Investment Authority, fund, authority, foundation, commission, agency or other entity that was established under the law of that Contracting State and that is wholly-owned and controlled by the Government of that Contracting State or a political subdivision or local authority thereof, by any entity referred to in this subparagraph or by any combination thereof; and (c) any entity established in that Contracting State all the capital of which has been provided by the Government of that Contracting State or a political subdivision or local authority thereof either alone or together with the governments of other states.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (a)
(a) the Government of that Contracting State or a political subdivision or local Government or local authority thereof; and
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (b)
(b) any corporation, Central Bank, Abu Dhabi Investment Authority, fund, authority, foundation, commission, agency or other entity that was established under the law of that Contracting State and that is wholly-owned and controlled by the Government of that Contracting State or a political subdivision or local authority thereof, by any entity referred to in this subparagraph or by any combination thereof; and
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (c)
(c) any entity established in that Contracting State all the capital of which has been provided by the Government of that Contracting State or a political subdivision or local authority thereof either alone or together with the governments of other states.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 3
3 Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then the individual’s status shall be determined as follows: (a) the individual shall be deemed to be a resident only of the State in which the individual has a permanent home available; if the individual has a permanent home available in both States, the individual shall be deemed to be a resident only of the State with which the individual’s personal and economic relations are closer (centre of vital interests); (b) if the State in which the individual’s centre of vital interests is situated cannot be determined, or if there is not a permanent home available in either State, the individual shall be deemed to be a resident only of the State in which the individual has an habitual abode; (c) if the individual has an habitual abode in both States or in neither of them, the individual shall be deemed to be a resident only of the State of which the individual is a national; (d) if the individual 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.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (a)
(a) the individual shall be deemed to be a resident only of the State in which the individual has a permanent home available; if the individual has a permanent home available in both States, the individual shall be deemed to be a resident only of the State with which the individual’s personal and economic relations are closer (centre of vital interests);
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (b)
(b) if the State in which the individual’s centre of vital interests is situated cannot be determined, or if there is not a permanent home available in either State, the individual shall be deemed to be a resident only of the State in which the individual has an habitual abode;
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (c)
(c) if the individual has an habitual abode in both States or in neither of them, the individual shall be deemed to be a resident only of the State of which the individual is a national;
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (d)
(d) if the individual 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.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 4
4 Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident only of the Contracting State of which it is a national.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 1
1 For the purposes of this Convention, the term permanent establishment means a fixed place of business through which the business of an enterprise is wholly or partly carried on.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 2
2 The term permanent establishment includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place relating to the exploration for or the exploitation of natural resources.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (f)
(f) a mine, an oil or gas well, a quarry or any other place relating to the exploration for or the exploitation of natural resources.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 3
3 A building site or construction or installation project constitutes a permanent establishment only if it lasts for more than twelve months.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 4
4 Notwithstanding the preceding provisions of this Article, the term permanent establishment shall be deemed not to include: (a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise; (b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery; (c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; (d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs (a) to (e) provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (a)
(a) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise;
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (b)
(b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage, display or delivery;
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (c)
(c) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise;
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (d)
(d) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise or of collecting information, for the enterprise;
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (e)
(e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character;
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (f)
(f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs (a) to (e) provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 5
5 Notwithstanding the provisions of paragraphs 1 and 2, where a person — other than an agent of an independent status to whom paragraph 6 applies — is acting on behalf of an enterprise and has, and habitually exercises in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 6
6 An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly to the business of that enterprise, such agent shall not be considered an agent of an independent status within the meaning of this paragraph.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 7
7 The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 1
1 Income derived by a resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 2
2 For the purposes of this Convention, the term immovable property shall have the meaning which it has under the taxation law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources; ships and aircraft shall not be regarded as immovable property.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 3
3 The provisions of paragraph l shall apply to income derived from the direct use, letting, or use in any other form of immovable property.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 4
4 The provisions of paragraphs l and 3 shall also apply to the income from immovable property of an enterprise and to income from immovable property used for the performance of independent personal services.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 1
1 The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on or has carried on business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 2
2 Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 3
3 In the determination of the profits of a permanent establishment, there shall be allowed those deductible expenses which are incurred for the purposes of the permanent establishment including executive and general administrative expenses, whether incurred in the Contracting State in which the permanent establishment is situated or elsewhere.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 4
4 No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 5
5 For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 6
6 Where profits include items of income which are dealt with separately in other Articles of this Convention, then the provisions of those Articles shall not be affected by the provisions of this Article.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 1
1 Profits derived by an enterprise of a Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 2
2 Notwithstanding the provisions of Article 7, profits derived by an enterprise of a Contracting State from a voyage of a ship or aircraft where the principal purpose of the voyage is to transport passengers or property between places in the other Contracting State may be taxed in that other State.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 3
3 The provisions of paragraphs 1 and 2 shall also apply to profits referred to in those paragraphs derived by an enterprise of a Contracting State from the participation in a pool, a joint business or an international operating agency.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 4
4 In this Article, (a) the term profits includes: (i) gross receipts and revenues derived directly from the operation of ships or aircraft in international traffic, and (ii) interest that is incidental to the operation of ships or aircraft in international traffic; (b) the term operation of ships or aircraft in international traffic by an enterprise, includes: (i) the charter or rental of ships or aircraft, (ii) the rental of containers and related equipment, and (iii) the alienation of ships, aircraft, containers and related equipment, by that enterprise provided that such charter, rental or alienation is incidental to the operation by that enterprise of ships or aircraft in international traffic.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (a)
(a) the term profits includes: (i) gross receipts and revenues derived directly from the operation of ships or aircraft in international traffic, and (ii) interest that is incidental to the operation of ships or aircraft in international traffic;
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (i)
(i) gross receipts and revenues derived directly from the operation of ships or aircraft in international traffic, and
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (ii)
(ii) interest that is incidental to the operation of ships or aircraft in international traffic;
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (b)
(b) the term operation of ships or aircraft in international traffic by an enterprise, includes: (i) the charter or rental of ships or aircraft, (ii) the rental of containers and related equipment, and (iii) the alienation of ships, aircraft, containers and related equipment, by that enterprise provided that such charter, rental or alienation is incidental to the operation by that enterprise of ships or aircraft in international traffic.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (i)
(i) the charter or rental of ships or aircraft,
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (ii)
(ii) the rental of containers and related equipment, and
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (iii)
(iii) the alienation of ships, aircraft, containers and related equipment,
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55
by that enterprise provided that such charter, rental or alienation is incidental to the operation by that enterprise of ships or aircraft in international traffic.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 1
1 Where (a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or (b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (a)
(a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or
Canada — United Arab Emirates Tax Convention Act, 2002 — C-10.55 (b)
(b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State,