GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Canada–Armenia Tax Convention Act, 2004 — C-0.7 3
3 Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Canada–Armenia Tax Convention Act, 2004 — C-0.7
Directors’ fees and other similar payments derived by a resident of a Contracting State in the capacity as a member of the board of directors or a similar organ of a company which is a resident of the other Contracting State may be taxed in that other State.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 1
1 Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsperson, from that resident’s personal activities as such exercised in the other Contracting State, may be taxed in that other State.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 2
2 Where income in respect of personal activities exercised by an entertainer or a sportsperson in that individual’s capacity as such accrues not to the entertainer or sportsperson personally but to another person, that income may, notwithstanding the provisions of Articles 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 3
3 The provisions of paragraph 2 shall not apply if it is established that neither the entertainer or the sportsperson nor persons related thereto participate directly or indirectly in the profits of the person referred to in that paragraph.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 4
4 Notwithstanding the provisions of paragraphs 1 and 2, income derived by an entertainer or a sportsperson from the activities referred to in paragraph 1, performed within the framework of cultural or sport exchanges agreed to by the Governments of the Contracting States and carried out other than for the purpose of profit, shall be exempt from tax in the Contracting State in which these activities are exercised.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 1
1 Pensions arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 2
2 Pensions arising in a Contracting State and paid to a resident of the other Contracting State may also be taxed in the State in which they arise and according to the laws of that State. However, in the case of periodic pension payments, other than payments under the social security legislation in a Contracting State, the tax so charged shall not exceed the lesser of: (a) 15 per cent of the gross amount of the payment; and (b) the rate determined by reference to the amount of tax that the recipient of the payment would otherwise be required to pay for the year on the total amount of the periodic pension payments received by the individual in the year, if the individual were resident in the Contracting State in which the payment arises.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (a)
(a) 15 per cent of the gross amount of the payment; and
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (b)
(b) the rate determined by reference to the amount of tax that the recipient of the payment would otherwise be required to pay for the year on the total amount of the periodic pension payments received by the individual in the year, if the individual were resident in the Contracting State in which the payment arises.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 3
3 Notwithstanding anything in this Convention, (a) war pensions and allowances (including pensions and allowances paid to war veterans or paid as a consequence of damages or injuries suffered as a consequence of a war) arising in a Contracting State and paid to a resident of the other Contracting State shall be exempt from tax in that other State to the extent that they would be exempt from tax if received by a resident of the first-mentioned State; (b) benefits under the social security legislation in a Contracting State paid to a resident of the other Contracting State shall be taxable only in the first-mentioned State; and (c) alimony and other similar payments arising in a Contracting State and paid to a resident of the other Contracting State who is subject to tax therein in respect thereof shall be taxable only in that other State, but the amount taxable in that other State shall not exceed the amount that would be taxable in the first-mentioned State if the recipient were a resident thereof.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (a)
(a) war pensions and allowances (including pensions and allowances paid to war veterans or paid as a consequence of damages or injuries suffered as a consequence of a war) arising in a Contracting State and paid to a resident of the other Contracting State shall be exempt from tax in that other State to the extent that they would be exempt from tax if received by a resident of the first-mentioned State;
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (b)
(b) benefits under the social security legislation in a Contracting State paid to a resident of the other Contracting State shall be taxable only in the first-mentioned State; and
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (c)
(c) alimony and other similar payments arising in a Contracting State and paid to a resident of the other Contracting State who is subject to tax therein in respect thereof shall be taxable only in that other State, but the amount taxable in that other State shall not exceed the amount that would be taxable in the first-mentioned State if the recipient were a resident thereof.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 1. (a)
1. (a) Salaries, wages and other similar remuneration, other than a pension, paid by a Contracting State or a political or administrative-territorial subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State. (b) However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who: (i) is a national of that State, or (ii) did not become a resident of that State solely for the purpose of rendering the services.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (b)
(b) However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who: (i) is a national of that State, or
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (ii)
(ii) did not become a resident of that State solely for the purpose of rendering the services.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 2
2 The provisions of paragraph 1 shall not apply to salaries, wages and other similar remuneration in respect of services rendered in connection with a business carried on by a Contracting State or a political or administrative-territorial subdivision or a local authority thereof.
Canada–Armenia Tax Convention Act, 2004 — C-0.7
Payments which a student or business apprentice who is, or was immediately before visiting a Contracting State, a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of that individual’s education or training receives for the purpose of that individual’s maintenance, education or training shall not be taxed in that State, if such payments arise from sources outside that State.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 1
1 Subject to the provisions of paragraph 2, items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 2
2 However, if such income is derived by a resident of a Contracting State from sources in the other Contracting State, such income may also be taxed in the State in which it arises and according to the law of that State. Where such income is income from a trust, other than a trust to which contributions were deductible, the tax so charged shall, if the income is taxable in the Contracting State in which the beneficial owner is a resident, not exceed 15 per cent of the gross amount of the income.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 1
1 Capital represented by immovable property owned by a resident of a Contracting State and situated in the other Contracting State may be taxed in that other State.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 2
2 Capital represented by movable property forming part of the business property of a permanent establishment that an enterprise of a Contracting State has in the other Contracting State, or by movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, may be taxed in that other State.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 3
3 Capital represented by ships and aircraft operated by an enterprise of a Contracting State in international traffic and by movable property pertaining to the operation of such ships and aircraft shall be taxable only in that State.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 4
4 All other elements of capital of a resident of a Contracting State shall be taxable only in that State.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 1
1 In the case of Canada, double taxation shall be avoided as follows: (a) subject to the existing provisions of the law of Canada regarding the deduction from tax payable in Canada of tax paid in a territory outside Canada and to any subsequent modification of those provisions — which shall not affect the general principle hereof — and unless a greater deduction or relief is provided under the laws of Canada, tax payable in Armenia on profits, income or gains arising in Armenia shall be deducted from any Canadian tax payable in respect of such profits, income or gains; (b) subject to the existing provisions of the law of Canada regarding the allowance as a credit against Canadian tax of tax payable in a territory outside Canada and to any subsequent modification of those provisions — which shall not affect the general principal hereof — where a company which is a resident of Armenia pays a dividend to a company which is a resident of Canada and which controls directly or indirectly at least 10 per cent of the voting power in the first-mentioned company, the credit shall take into account the tax payable in Armenia by that first-mentioned company in respect of the profits out of which such dividend is paid; and (c) where, in accordance with any provision of the Convention, income derived or capital owned by a resident of Canada is exempt from tax in Canada, Canada may nevertheless, in calculating the amount of tax on other income or capital, take into account the exempted income or capital.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (a)
(a) subject to the existing provisions of the law of Canada regarding the deduction from tax payable in Canada of tax paid in a territory outside Canada and to any subsequent modification of those provisions — which shall not affect the general principle hereof — and unless a greater deduction or relief is provided under the laws of Canada, tax payable in Armenia on profits, income or gains arising in Armenia shall be deducted from any Canadian tax payable in respect of such profits, income or gains;
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (b)
(b) subject to the existing provisions of the law of Canada regarding the allowance as a credit against Canadian tax of tax payable in a territory outside Canada and to any subsequent modification of those provisions — which shall not affect the general principal hereof — where a company which is a resident of Armenia pays a dividend to a company which is a resident of Canada and which controls directly or indirectly at least 10 per cent of the voting power in the first-mentioned company, the credit shall take into account the tax payable in Armenia by that first-mentioned company in respect of the profits out of which such dividend is paid; and
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (c)
(c) where, in accordance with any provision of the Convention, income derived or capital owned by a resident of Canada is exempt from tax in Canada, Canada may nevertheless, in calculating the amount of tax on other income or capital, take into account the exempted income or capital.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 2
2 In the case of Armenia, double taxation shall be avoided as follows: (a) where a resident of Armenia derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in Canada, Armenia shall allow: (i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Canada, (ii) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in Canada. Such deduction in either case shall not, however, exceed that part of the income tax or capital tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in Canada. (b) subject to the existing provisions of the law of Armenia regarding the allowance as a credit against Armenian tax of tax payable in a territory outside Armenia and to any subsequent modification of those provisions — which shall not affect the general principle hereof — where a company which is a resident of Canada pays a dividend to a company which is a resident of Armenia and which holds directly or indirectly at least 10 per cent of the capital in the first-mentioned company, the credit shall take into account the tax payable in Canada by that first-mentioned company in respect of the profits out of which such dividend is paid; and (c) where in accordance with any provision of this Convention, income derived or capital owned by a resident of Armenia is exempt from tax in Armenia, Armenia may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (a)
(a) where a resident of Armenia derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in Canada, Armenia shall allow: (i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Canada, (ii) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in Canada. Such deduction in either case shall not, however, exceed that part of the income tax or capital tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in Canada.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (i)
(i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Canada,
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (ii)
(ii) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in Canada.
Canada–Armenia Tax Convention Act, 2004 — C-0.7
Such deduction in either case shall not, however, exceed that part of the income tax or capital tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in Canada.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (b)
(b) subject to the existing provisions of the law of Armenia regarding the allowance as a credit against Armenian tax of tax payable in a territory outside Armenia and to any subsequent modification of those provisions — which shall not affect the general principle hereof — where a company which is a resident of Canada pays a dividend to a company which is a resident of Armenia and which holds directly or indirectly at least 10 per cent of the capital in the first-mentioned company, the credit shall take into account the tax payable in Canada by that first-mentioned company in respect of the profits out of which such dividend is paid; and
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (c)
(c) where in accordance with any provision of this Convention, income derived or capital owned by a resident of Armenia is exempt from tax in Armenia, Armenia may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 3
3 For the purposes of this Article, profits, income or gains of a resident of a Contracting State that may be taxed in the other Contracting State in accordance with this Convention shall be deemed to arise from sources in that other State.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 1
1 Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith that is more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances, in particular with respect to residence, are or may be subjected.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 2
2 Stateless persons who are residents of a Contracting State shall not be subjected in either Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of the State concerned in the same circumstances are or may be subjected to.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 3
3 The taxation on a permanent establishment that an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 4
4 Nothing in this Article shall be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities that it grants to its own residents.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 5
5 Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article 11, or paragraph 6 of Article 12, apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State. Similarly, any debts of an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable capital of such enterprise, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 6
6 The provisions of paragraph 5 shall not affect the operation of any provision of the taxation laws of a Contracting State: (a) relating to the deductibility of interest and which is in force on the date of signature of this Convention (including any subsequent modification of such provisions that does not change the general nature thereof); or (b) adopted after such date by a Contracting State and which is designed to ensure that a person who is not a resident of that State does not enjoy, under the laws of that State, a tax treatment that is more favorable than that enjoyed by residents of that State.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (a)
(a) relating to the deductibility of interest and which is in force on the date of signature of this Convention (including any subsequent modification of such provisions that does not change the general nature thereof); or
Canada–Armenia Tax Convention Act, 2004 — C-0.7 (b)
(b) adopted after such date by a Contracting State and which is designed to ensure that a person who is not a resident of that State does not enjoy, under the laws of that State, a tax treatment that is more favorable than that enjoyed by residents of that State.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 7
7 Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith that is more burdensome than the taxation and connected requirements to which other similar enterprises that are residents of the first-mentioned State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of a third State, are or may be subjected.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 8
8 In this Article, the term taxation means taxes that are the subject of this Convention.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 1
1 Where a person considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with the provisions of this Convention, that person may, irrespective of the remedies provided by the domestic law of those States, address to the competent authority of the Contracting State of which that person is a resident an application in writing stating the grounds for claiming the revision of such taxation. To be admissible, the said application must be submitted within two years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 2
2 The competent authority referred to in paragraph 1 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. Any agreement reached within six years from the end of the taxable period in which the taxation not in accordance with the provisions of the Convention arose, shall be implemented notwithstanding any time limits in the domestic law of the Contracting States.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 3
3 A Contracting State shall not, after the expiry of the time limits provided in its domestic laws and, in any case, after five years from the end of the taxable period to which the income concerned was attributed, increase the tax base of a resident of either of the Contracting States by including therein items of income that have also been charged to tax in the other Contracting State. This paragraph shall not apply in the case of fraud, wilful default or neglect.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 4
4 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.
Canada–Armenia Tax Convention Act, 2004 — C-0.7 5
5 The competent authorities of the Contracting States may consult together for the elimination of double taxation in cases not provided for in the Convention and may communicate with each other directly for the purpose of applying the Convention.