GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Income Tax Conventions Implementation Act, 1999 — I-3.54 2
2 The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation not in accordance with the Convention.
Income Tax Conventions Implementation Act, 1999 — I-3.54 3
3 The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Convention. They may also consult together for the elimination of double taxation in cases not provided for in the Convention.
Income Tax Conventions Implementation Act, 1999 — I-3.54 4
4 The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisable in order to reach an agreement to have an oral exchange of opinions, such exchange may take place through a Commission consisting of representatives of the competent authorities of the Contracting States.
Income Tax Conventions Implementation Act, 1999 — I-3.54 1
1 The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Convention or of the domestic laws in the Contracting States concerning taxes covered by the Convention insofar as the taxation thereunder is not contrary to the Convention. The exchange of information is not restricted by Article 1. Any information received by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to, taxes. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions.
Income Tax Conventions Implementation Act, 1999 — I-3.54 2
2 In no case shall the provisions of paragraph 1 be construed so as to impose on a Contracting State the obligation: (a) to carry out administrative measures at variance with the laws and the administrative practice of that or of the other Contracting State; (b) to supply information that is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; or (c) to supply information that would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).
Income Tax Conventions Implementation Act, 1999 — I-3.54 (b)
(b) to supply information that is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; or
Income Tax Conventions Implementation Act, 1999 — I-3.54 (c)
(c) to supply information that would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).
Income Tax Conventions Implementation Act, 1999 — I-3.54 3
3 If information is requested by a Contracting State in accordance with this Article, the other Contracting State shall endeavour to obtain the information to which the request relates in the same way as if its own taxation were involved, even though the other State does not, at that time, need such information.
Income Tax Conventions Implementation Act, 1999 — I-3.54
Nothing in this Convention shall affect the fiscal privileges of diplomatic agents or consular officers under the general rules of international law or under the provisions of special agreements.
Income Tax Conventions Implementation Act, 1999 — I-3.54 1
1 This Convention shall be ratified and the instruments of ratification shall be exchanged as soon as possible.
Income Tax Conventions Implementation Act, 1999 — I-3.54 2
2 The Convention shall enter into force upon the exchange of instruments of ratification 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 following that in which the Convention 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 in which the Convention enters into force; (b) in Algeria: (i) to taxes withheld at the source on income credited or payable on or after the first day of January in the calendar year following that in which the Convention enters into force; and (ii) to other taxes for taxable periods beginning on or after the first day of January in the calendar year in which the Convention enters into force.
Income Tax Conventions Implementation Act, 1999 — I-3.54 (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 following that in which the Convention 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 in which the Convention enters into force;
Income Tax Conventions Implementation Act, 1999 — I-3.54 (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 following that in which the Convention enters into force; and
Income Tax Conventions Implementation Act, 1999 — I-3.54 (ii)
(ii) in respect of other Canadian tax for taxation years, beginning on or after the first day of January in the calendar year in which the Convention enters into force;
Income Tax Conventions Implementation Act, 1999 — I-3.54 (b)
(b) in Algeria: (i) to taxes withheld at the source on income credited or payable on or after the first day of January in the calendar year following that in which the Convention enters into force; and (ii) to other taxes for taxable periods beginning on or after the first day of January in the calendar year in which the Convention enters into force.
Income Tax Conventions Implementation Act, 1999 — I-3.54 (i)
(i) to taxes withheld at the source on income credited or payable on or after the first day of January in the calendar year following that in which the Convention enters into force; and
Income Tax Conventions Implementation Act, 1999 — I-3.54 (ii)
(ii) to other taxes for taxable periods beginning on or after the first day of January in the calendar year in which the Convention enters into force.
Income Tax Conventions Implementation Act, 1999 — I-3.54
This Convention shall continue in effect as long as it has not been terminated by a Contracting State. Either Contracting State may, through diplomatic channels, terminate the Convention by giving a six-month notice before the end of any calendar year beginning after the fifth year from the date of entry into force of the Convention.
Income Tax Conventions Implementation Act, 1999 — I-3.54 (a)
In such event, the Convention shall cease to 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 of the calendar year next following that of the termination; and (ii) in respect of other Canadian tax for taxation years, beginning on or after the first day of January of the calendar year next following that of the termination; (b) in Algeria: (i) to taxes withheld at the source on income credited or payable at the latest on December 31 of the year of the termination; and (ii) to other taxes for taxable periods ending on or before December 31 of the same year.
Income Tax Conventions Implementation Act, 1999 — I-3.54 (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 of the calendar year next following that of the termination; and (ii) in respect of other Canadian tax for taxation years, beginning on or after the first day of January of the calendar year next following that of the termination;
Income Tax Conventions Implementation Act, 1999 — I-3.54 (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 of the calendar year next following that of the termination; and
Income Tax Conventions Implementation Act, 1999 — I-3.54 (ii)
(ii) in respect of other Canadian tax for taxation years, beginning on or after the first day of January of the calendar year next following that of the termination;
Income Tax Conventions Implementation Act, 1999 — I-3.54 (b)
(b) in Algeria: (i) to taxes withheld at the source on income credited or payable at the latest on December 31 of the year of the termination; and (ii) to other taxes for taxable periods ending on or before December 31 of the same year.
Income Tax Conventions Implementation Act, 1999 — I-3.54 (i)
(i) to taxes withheld at the source on income credited or payable at the latest on December 31 of the year of the termination; and
Income Tax Conventions Implementation Act, 1999 — I-3.54 (ii)
(ii) to other taxes for taxable periods ending on or before December 31 of the same year.
Income Tax Conventions Implementation Act, 1999 — I-3.54
DONE in duplicate at Algiers, this 28th day of February 1999, in the English, French and Arabic languages, each version being equally authentic.
Income Tax Conventions Implementation Act, 1999 — I-3.54
Ambassador of Canada to the People’s Democratic Republic of Algeria
Income Tax Conventions Implementation Act, 1999 — I-3.54
Minister Delegate to the Minister of Foreign Affairs in charge of Cooperation and Maghreb Affairs
Income Tax Conventions Implementation Act, 1999 — I-3.54
At the moment of signing the Convention between the Government of Canada and the Government of the People’s Democratic Republic of Algeria for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital the undersigned, duly authorized, have agreed on the following provisions which shall be an integral part of the Convention.
Income Tax Conventions Implementation Act, 1999 — I-3.54 1
1 With reference to paragraph 1 of Article 2 It is understood that, in the case of Algeria, the Convention shall also apply to taxes on income and on capital imposed on behalf of its political subdivisions or local authorities.
Income Tax Conventions Implementation Act, 1999 — I-3.54
It is understood that, in the case of Algeria, the Convention shall also apply to taxes on income and on capital imposed on behalf of its political subdivisions or local authorities.
Income Tax Conventions Implementation Act, 1999 — I-3.54 2
2 With respect to paragraph 1 (d) of Article 3 It is understood that the term person also includes, in the case of Canada, a trust and an estate.
Income Tax Conventions Implementation Act, 1999 — I-3.54
It is understood that the term person also includes, in the case of Canada, a trust and an estate.
Income Tax Conventions Implementation Act, 1999 — I-3.54 3
3 With reference to paragraph 1 of Article 4 It is understood that the term resident of a Contracting State also includes any agency or instrumentality of a Contracting State, its political subdivisions or its local authorities.
Income Tax Conventions Implementation Act, 1999 — I-3.54
It is understood that the term resident of a Contracting State also includes any agency or instrumentality of a Contracting State, its political subdivisions or its local authorities.
Income Tax Conventions Implementation Act, 1999 — I-3.54 4
4 With reference to paragraph 1 of Article 6 It is understood that the provisions of paragraph 1 of Article 6 shall also apply to income from the alienation of property referred to therein.
Income Tax Conventions Implementation Act, 1999 — I-3.54
It is understood that the provisions of paragraph 1 of Article 6 shall also apply to income from the alienation of property referred to therein.
Income Tax Conventions Implementation Act, 1999 — I-3.54 5
5 Notwithstanding the provisions of paragraph 2 of Article 11, interest arising in Algeria and paid to a resident of Canada shall be taxable only in Canada if it is paid in respect of a loan guaranteed or insured, or a credit guaranteed or insured by the Export Development Corporation.
Income Tax Conventions Implementation Act, 1999 — I-3.54 6
6 Notwithstanding the provisions of paragraph 4 of Article 13, gains derived by a resident of Algeria from the alienation of: (a) shares (other than shares listed on an approved stock exchange in Canada) of the capital stock of a company the value of which shares is derived principally from immovable property situated in Canada; or (b) an interest in a partnership, trust or estate, the value of which is derived principally from immovable property situated in Canada, may be taxed in Canada. For the purposes of this paragraph, the term immovable property includes the shares of a company referred to in subparagraph (a) or an interest in a partnership, trust or estate referred to in subparagraph (b).
Income Tax Conventions Implementation Act, 1999 — I-3.54 (a)
(a) shares (other than shares listed on an approved stock exchange in Canada) of the capital stock of a company the value of which shares is derived principally from immovable property situated in Canada; or
Income Tax Conventions Implementation Act, 1999 — I-3.54 (b)
(b) an interest in a partnership, trust or estate, the value of which is derived principally from immovable property situated in Canada,
Income Tax Conventions Implementation Act, 1999 — I-3.54
may be taxed in Canada. For the purposes of this paragraph, the term immovable property includes the shares of a company referred to in subparagraph (a) or an interest in a partnership, trust or estate referred to in subparagraph (b).
Income Tax Conventions Implementation Act, 1999 — I-3.54 7
7 Where an individual who ceases to be a resident of a Contracting State, and immediately thereafter becomes a resident of the other Contracting State, is treated for the purposes of taxation in the first-mentioned State as having alienated a property and is taxed in that State by reason thereof, the individual may elect to be treated for the purposes of taxation in the other State as if the individual had, immediately before becoming a resident of that State, sold and repurchased the property for an amount equal to its fair market value at that time.
Income Tax Conventions Implementation Act, 1999 — I-3.54 8
8 Notwithstanding any provision of the Convention, (a) a company that is a resident of Algeria and that has a permanent establishment in Canada shall, in accordance with the provisions of Canadian law, remain subject to the additional tax on companies other than Canadian companies, but the rate of such tax shall not exceed 15 per cent; (b) a company that is a resident of Canada and that has a permanent establishment in Algeria shall remain subject to the withholding tax in accordance with the provisions of Algerian law, but the rate of such tax shall not exceed 15 per cent.
Income Tax Conventions Implementation Act, 1999 — I-3.54 (a)
(a) a company that is a resident of Algeria and that has a permanent establishment in Canada shall, in accordance with the provisions of Canadian law, remain subject to the additional tax on companies other than Canadian companies, but the rate of such tax shall not exceed 15 per cent;
Income Tax Conventions Implementation Act, 1999 — I-3.54 (b)
(b) a company that is a resident of Canada and that has a permanent establishment in Algeria shall remain subject to the withholding tax in accordance with the provisions of Algerian law, but the rate of such tax shall not exceed 15 per cent.
Income Tax Conventions Implementation Act, 1999 — I-3.54 9
9 The provisions of the Convention shall not be construed to restrict in any manner any exemption, allowance, credit or other deduction accorded (a) by the laws of a Contracting State in the determination of the tax imposed by that State; or (b) by any other agreement entered into by a Contracting State.
Income Tax Conventions Implementation Act, 1999 — I-3.54 10
10 Nothing in the Convention shall be construed as preventing Canada from imposing a tax on amounts included in the income of a resident of Canada with respect to a partnership, trust, or controlled foreign affiliate, in which that resident has an interest.
Income Tax Conventions Implementation Act, 1999 — I-3.54 11
11 The Convention shall not apply to any company, trust or partnership that is a resident of a Contracting State and is beneficially owned or controlled, directly or indirectly, by one or more persons who are not residents of that State, if the amount of the tax imposed on the income or capital of the company, trust or partnership by that State is substantially lower than the amount that would be imposed by that State if all of the shares of the capital stock of the company or all of the interests in the trust or partnership, as the case may be, were beneficially owned by one or more individuals who were residents of that State.
Income Tax Conventions Implementation Act, 1999 — I-3.54 12
12 The Contracting States agree that any dispute between them as to whether a measure falls within the scope of this Convention may be brought before the Council for Trade in Services, as provided by paragraph 3 of Article XXII (Consultation) of the General Agreement on Trade in Services, only with the consent of both Contracting States. Any doubt as to the interpretation of this paragraph shall be resolved under paragraph 3 of Article 25 or, failing agreement, pursuant to any other procedure agreed to by both Contracting States.
Income Tax Conventions Implementation Act, 1999 — I-3.54
The Government of Canada and the Government of the Republic of Bulgaria, hereinafter referred to as “Contracting States”, desiring to further develop and facilitate their mutual economic relationship and desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, have agreed as follows:
Income Tax Conventions Implementation Act, 1999 — I-3.54 3
3 The existing taxes to which the Convention shall apply are, in particular: (a) in the case of Canada: the income and capital taxes imposed by the Government of Canada under the Income Tax Act , (hereinafter referred to as “Canadian tax”); (b) in the case of the Republic of Bulgaria: (i) individual income tax, (ii) corporate income tax, and (iii) real property tax, (hereinafter referred to as “Bulgarian tax”).
Income Tax Conventions Implementation Act, 1999 — I-3.54 (a)
(a) in the case of Canada: the income and capital taxes imposed by the Government of Canada under the Income Tax Act , (hereinafter referred to as “Canadian tax”);
Income Tax Conventions Implementation Act, 1999 — I-3.54
the income and capital taxes imposed by the Government of Canada under the Income Tax Act , (hereinafter referred to as “Canadian tax”);
Income Tax Conventions Implementation Act, 1999 — I-3.54 (b)
(b) in the case of the Republic of Bulgaria: (i) individual income tax, (ii) corporate income tax, and (iii) real property tax, (hereinafter referred to as “Bulgarian tax”).
Income Tax Conventions Implementation Act, 1999 — I-3.54
(hereinafter referred to as “Bulgarian tax”).
Income Tax Conventions Implementation Act, 1999 — I-3.54 4
4 The Convention shall apply also to any substantially similar taxes and to taxes on capital which are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes as well as to any other tax as may be specified and agreed in letters exchanged between the competent authorities of the Contracting States. The competent authorities of the Contracting States shall notify each other of any significant changes which have been made in their respective taxation laws.
Income Tax Conventions Implementation Act, 1999 — I-3.54 1
1 In this Convention, unless the context otherwise requires: (a) the terms: (i) Canada , used in a geographical sense, means the territory of Canada, including 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, (ii) Bulgaria means the Republic of Bulgaria and, when used in a geographical sense, means the territory and the territorial sea over which it exercises its State sovereignty, as well as the continental shelf and the exclusive economic zone over which it exercises sovereign rights or jurisdiction in conformity with international law; (b) the terms a Contracting State and the other Contracting State mean, as the context requires, Canada or Bulgaria; (c) the term person includes an individual and: (i) in the case of Canada, a trust, a company and any other body of persons, (ii) in the case of Bulgaria, any legal person, including a company 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 term competent authority means: (i) in the case of Canada, the Minister of National Revenue or the Minister’s authorized representative, (ii) in the case of Bulgaria, the Minister of Finance or his authorized representative; (f) the term national means: (i) any individual possessing the nationality of a Contracting State, (ii) any legal person or body of persons deriving its status from the laws in force in a Contracting State; (g) the term tax means Canadian tax or Bulgarian tax, as the context requires; (h) the term international traffic means any transport by a ship or aircraft operated by a resident of a Contracting State, except where the ship or aircraft is operated solely between places in the other Contracting State.
Income Tax Conventions Implementation Act, 1999 — I-3.54 (a)
(a) the terms: (i) Canada , used in a geographical sense, means the territory of Canada, including 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, (ii) Bulgaria means the Republic of Bulgaria and, when used in a geographical sense, means the territory and the territorial sea over which it exercises its State sovereignty, as well as the continental shelf and the exclusive economic zone over which it exercises sovereign rights or jurisdiction in conformity with international law;
Income Tax Conventions Implementation Act, 1999 — I-3.54 (i)
(i) Canada , used in a geographical sense, means the territory of Canada, including 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,
Income Tax Conventions Implementation Act, 1999 — I-3.54 (ii)
(ii) Bulgaria means the Republic of Bulgaria and, when used in a geographical sense, means the territory and the territorial sea over which it exercises its State sovereignty, as well as the continental shelf and the exclusive economic zone over which it exercises sovereign rights or jurisdiction in conformity with international law;
Income Tax Conventions Implementation Act, 1999 — I-3.54 (b)
(b) the terms a Contracting State and the other Contracting State mean, as the context requires, Canada or Bulgaria;
Income Tax Conventions Implementation Act, 1999 — I-3.54 (c)
(c) the term person includes an individual and: (i) in the case of Canada, a trust, a company and any other body of persons, (ii) in the case of Bulgaria, any legal person, including a company and any other body of persons;