GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains
DONE in duplicate at London, this 21st day of July 2014, in the English and French languages, each version being equally authentic.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains
FOR THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — 1
At the signing of the Protocol amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains , signed at London on 8 September 1978, as amended by the Protocol signed at Ottawa on 15 April 1980, by the Protocol signed at London on 16 October 1985 and by the Protocol signed at London on 7 May 2003 (hereinafter referred to as the “Convention”), the undersigned have agreed upon the following provisions which shall form an integral part of the Convention: 1 In relation to the application of the Convention to United Kingdom Limited Liability Partnerships: It is understood that for the purpose of providing benefits under the Convention in respect of income or gains derived by or through a Limited Liability Partnership which is established under the laws of the United Kingdom, has its place of effective management in the United Kingdom, and is treated as fiscally transparent under the tax laws of the United Kingdom, the income or gains shall be considered to be income or gains of the members of the Limited Liability Partnership, but only to the extent that the income or gains are treated, for purposes of taxation by the United Kingdom, as the income or gains of a resident of the United Kingdom. In no case shall the provisions of this paragraph be construed so as to restrict in any way a Contracting State’s right to tax the residents of that State. The competent authorities of the Contracting States may consult to determine the application of this paragraph. 2 In relation to paragraph 1 of Article 4 of the Convention: It is understood that the word instrumentality includes a person that is wholly owned, directly or indirectly, by a Contracting State or a political subdivision or local authority of a Contracting State. 3 For the purposes of paragraph 3(c) of Article 11 of the Convention, it is understood that: (a) in the case of Canada, whether persons are considered to be dealing at arm’s length with each other, or not, is determined by subsection 251(1) of the Income Tax Act ; (b) in the case of the United Kingdom, persons are considered not to be dealing at arm’s length where: (i) one person is treated as having control of another person as defined in section 450 or section 1124 of Corporation Tax Act 2010 ; (ii) persons are associates or connected persons as defined by section 448 or section 1122 of Corporation Tax Act 2010 ; or (iii) neither subparagraph (i) nor subparagraph (ii) applies and conditions are made or imposed between those persons which does not reflect ordinary commercial dealing between persons acting in their separate interests.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — 1
1 In relation to the application of the Convention to United Kingdom Limited Liability Partnerships: It is understood that for the purpose of providing benefits under the Convention in respect of income or gains derived by or through a Limited Liability Partnership which is established under the laws of the United Kingdom, has its place of effective management in the United Kingdom, and is treated as fiscally transparent under the tax laws of the United Kingdom, the income or gains shall be considered to be income or gains of the members of the Limited Liability Partnership, but only to the extent that the income or gains are treated, for purposes of taxation by the United Kingdom, as the income or gains of a resident of the United Kingdom. In no case shall the provisions of this paragraph be construed so as to restrict in any way a Contracting State’s right to tax the residents of that State. The competent authorities of the Contracting States may consult to determine the application of this paragraph.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains
It is understood that for the purpose of providing benefits under the Convention in respect of income or gains derived by or through a Limited Liability Partnership which is established under the laws of the United Kingdom, has its place of effective management in the United Kingdom, and is treated as fiscally transparent under the tax laws of the United Kingdom, the income or gains shall be considered to be income or gains of the members of the Limited Liability Partnership, but only to the extent that the income or gains are treated, for purposes of taxation by the United Kingdom, as the income or gains of a resident of the United Kingdom. In no case shall the provisions of this paragraph be construed so as to restrict in any way a Contracting State’s right to tax the residents of that State. The competent authorities of the Contracting States may consult to determine the application of this paragraph.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — 2
2 In relation to paragraph 1 of Article 4 of the Convention: It is understood that the word instrumentality includes a person that is wholly owned, directly or indirectly, by a Contracting State or a political subdivision or local authority of a Contracting State.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains
It is understood that the word instrumentality includes a person that is wholly owned, directly or indirectly, by a Contracting State or a political subdivision or local authority of a Contracting State.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — 3
3 For the purposes of paragraph 3(c) of Article 11 of the Convention, it is understood that: (a) in the case of Canada, whether persons are considered to be dealing at arm’s length with each other, or not, is determined by subsection 251(1) of the Income Tax Act ; (b) in the case of the United Kingdom, persons are considered not to be dealing at arm’s length where: (i) one person is treated as having control of another person as defined in section 450 or section 1124 of Corporation Tax Act 2010 ; (ii) persons are associates or connected persons as defined by section 448 or section 1122 of Corporation Tax Act 2010 ; or (iii) neither subparagraph (i) nor subparagraph (ii) applies and conditions are made or imposed between those persons which does not reflect ordinary commercial dealing between persons acting in their separate interests.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — (a)
(a) in the case of Canada, whether persons are considered to be dealing at arm’s length with each other, or not, is determined by subsection 251(1) of the Income Tax Act ;
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — (b)
(b) in the case of the United Kingdom, persons are considered not to be dealing at arm’s length where: (i) one person is treated as having control of another person as defined in section 450 or section 1124 of Corporation Tax Act 2010 ; (ii) persons are associates or connected persons as defined by section 448 or section 1122 of Corporation Tax Act 2010 ; or (iii) neither subparagraph (i) nor subparagraph (ii) applies and conditions are made or imposed between those persons which does not reflect ordinary commercial dealing between persons acting in their separate interests.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — (i)
(i) one person is treated as having control of another person as defined in section 450 or section 1124 of Corporation Tax Act 2010 ;
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — (ii)
(ii) persons are associates or connected persons as defined by section 448 or section 1122 of Corporation Tax Act 2010 ; or
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — (iii)
(iii) neither subparagraph (i) nor subparagraph (ii) applies and conditions are made or imposed between those persons which does not reflect ordinary commercial dealing between persons acting in their separate interests.
Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains — Proclamation Giving Notice of the Entry into Force on December 18, 2014 of the Annexed Supplementary Convention, signed on July 21, 2014 and intended to alter the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains
IN WITNESS WHEREOF the undersigned, duly authorised thereto, have signed this Interpretative Protocol.
Transfer of Duties Order — a
His Excellency the Governor General in Council, on the recommendation of the Prime Minister, effective November 4, 2015, (a) pursuant to paragraph 2(a) a of the Public Service Rearrangement and Transfer of Duties Act b , transfers to the Minister of Infrastructure, Communities and Intergovernmental Affairs from the President of the Queen’s Privy Council for Canada the control and supervision of that portion of the federal public administration known as the Office of Infrastructure of Canada; and a S.C. 2003, c. 22, s. 207 b R.S., c. P-34 (b) orders that the Minister of Infrastructure, Communities and Intergovernmental Affairs is to preside over the Office of Infrastructure of Canada.
Transfer of Duties Order — a
(a) pursuant to paragraph 2(a) a of the Public Service Rearrangement and Transfer of Duties Act b , transfers to the Minister of Infrastructure, Communities and Intergovernmental Affairs from the President of the Queen’s Privy Council for Canada the control and supervision of that portion of the federal public administration known as the Office of Infrastructure of Canada; and a S.C. 2003, c. 22, s. 207 b R.S., c. P-34
Transfer of Duties Order — Transfer of Duties Order
(b) orders that the Minister of Infrastructure, Communities and Intergovernmental Affairs is to preside over the Office of Infrastructure of Canada.
Order Designating the Minister of Infrastructure, Communities and Intergovernmental Affairs as the Minister for the purposes of the Act — a
His Excellency the Governor General in Council, on the recommendation of the Prime Minister, pursuant to the definition Minister in section 2 of the Canada Strategic Infrastructure Fund Act a , effective November 4, 2015, a S.C. 2002, c. 9, s. 47 (a) repeals Order in Council P.C. 2014-376 of April 7, 2014 b ; and b SI/2014-41 (b) designates the Minister of Infrastructure, Communities and Intergovernmental Affairs, a member of the Queen’s Privy Council for Canada, as the Minister for the purposes of the Canada Strategic Infrastructure Fund Act a .
Order Designating the Minister of Infrastructure, Communities and Intergovernmental Affairs as the Minister for the purposes of the Act — (a)
(a) repeals Order in Council P.C. 2014-376 of April 7, 2014 b ; and b SI/2014-41
Order Designating the Minister of Infrastructure, Communities and Intergovernmental Affairs as the Minister for the purposes of the Act — (b)
(b) designates the Minister of Infrastructure, Communities and Intergovernmental Affairs, a member of the Queen’s Privy Council for Canada, as the Minister for the purposes of the Canada Strategic Infrastructure Fund Act a .
Transfer of Duties Order — a
His Excellency the Governor General in Council, on the recommendation of the Prime Minister, pursuant to paragraph 2(a) a of the Public Service Rearrangement and Transfer of Duties Act b , transfers from the Minister of Transport to the Minister of Infrastructure, Communities and Intergovernmental Affairs the powers, duties and functions under the Letters Patent of incorporation for the establishment of the Windsor-Detroit Bridge Authority issued by Order in Council P.C. 2012-1350 of October 9, 2012 c , except any power, duty or function under section 9.1 of those Letters Patent, effective November 4, 2015. a S.C. 2003, c. 22, s. 207 b R.S., c. P-34 c Canada Gazette , Part I, Vol. 147, No. 4, January 26, 2013
Order Designating the Minister of Infrastructure, Communities and Intergovernmental Affairs as the appropriate Minister for the Windsor-Detroit Bridge Authority — a
His Excellency the Governor General in Council, on the recommendation of the Prime Minister, pursuant to paragraph (d) of the definition appropriate Minister in section 2 of the Financial Administration Act a and subparagraph (a)(ii) of the definition appropriate Minister in subsection 83(1) of that Act, effective November 4, 2015, a R.S., c. F-11 (a) repeals Order in Council P.C. 2012-1352 of October 9, 2012 b ; and b SI/2012-78 (b) designates the Minister of Infrastructure, Communities and Intergovernmental Affairs, a member of the Queen’s Privy Council for Canada, as the appropriate Minister for the Windsor-Detroit Bridge Authority.
Order Designating the Minister of Infrastructure, Communities and Intergovernmental Affairs as the appropriate Minister for the Windsor-Detroit Bridge Authority — (a)
(a) repeals Order in Council P.C. 2012-1352 of October 9, 2012 b ; and b SI/2012-78
Order Designating the Minister of Infrastructure, Communities and Intergovernmental Affairs as the appropriate Minister for the Windsor-Detroit Bridge Authority — (b)
(b) designates the Minister of Infrastructure, Communities and Intergovernmental Affairs, a member of the Queen’s Privy Council for Canada, as the appropriate Minister for the Windsor-Detroit Bridge Authority.
Transfer of Duties Order — a
His Excellency the Governor General in Council, on the recommendation of the Prime Minister, pursuant to paragraph 2(a) a of the Public Service Rearrangement and Transfer of Duties Act b , transfers from the Minister of Transport to the Minister of Infrastructure, Communities and Intergovernmental Affairs the powers, duties and functions under the Bridge To Strengthen Trade Act c , effective November 4, 2015. a S.C. 2003, c. 22, s. 207 b R.S., c. P-34 c S.C. 2012, c. 31, s. 179
Order Designating the Minister of Infrastructure, Communities and Intergovernmental Affairs as the appropriate Minister for The Jacques-Cartier and Champlain Bridges Inc. — a
His Excellency the Governor General in Council, on the recommendation of the Prime Minister, pursuant to paragraph (d) of the definition appropriate Minister in section 2 of the Financial Administration Act a and subparagraph (a)(ii) of the definition appropriate Minister in subsection 83(1) of that Act, effective November 4, 2015, a R.S., c. F-11 (a) repeals Order in Council P.C. 2014-146 of February 10, 2014 b ; and b SI/2014-13 (b) designates the Minister of Infrastructure, Communities and Intergovernmental Affairs, a member of the Queen’s Privy Council for Canada, as the appropriate Minister for The Jacques-Cartier and Champlain Bridges Inc.
Order Designating the Minister of Infrastructure, Communities and Intergovernmental Affairs as the appropriate Minister for The Jacques-Cartier and Champlain Bridges Inc. — (a)
(a) repeals Order in Council P.C. 2014-146 of February 10, 2014 b ; and b SI/2014-13
Order Designating the Minister of Infrastructure, Communities and Intergovernmental Affairs as the appropriate Minister for The Jacques-Cartier and Champlain Bridges Inc. — (b)
(b) designates the Minister of Infrastructure, Communities and Intergovernmental Affairs, a member of the Queen’s Privy Council for Canada, as the appropriate Minister for The Jacques-Cartier and Champlain Bridges Inc.
Order Designating the Minister of Infrastructure, Communities and Intergovernmental Affairs to be the Minister for the purposes of the Act — a
His Excellency the Governor General in Council, on the recommendation of the Prime Minister, pursuant to section 3 of the New Bridge for the St. Lawrence Act a , effective November 4, 2015, a S.C. 2014, c. 20, s. 375 (a) repeals Order in Council P.C. 2014-857 of June 26, 2014 b ; and b SI/2014-63 (b) designates the Minister of Infrastructure, Communities and Intergovernmental Affairs, a member of the Queen’s Privy Council for Canada, to be the Minister for the purposes of the New Bridge for the St. Lawrence Act a .
Order Designating the Minister of Infrastructure, Communities and Intergovernmental Affairs to be the Minister for the purposes of the Act — (a)
(a) repeals Order in Council P.C. 2014-857 of June 26, 2014 b ; and b SI/2014-63
Order Designating the Minister of Infrastructure, Communities and Intergovernmental Affairs to be the Minister for the purposes of the Act — (b)
(b) designates the Minister of Infrastructure, Communities and Intergovernmental Affairs, a member of the Queen’s Privy Council for Canada, to be the Minister for the purposes of the New Bridge for the St. Lawrence Act a .
Transfer of Duties Order — a
His Excellency the Governor General in Council, on the recommendation of the Prime Minister, pursuant to paragraph 2(a) a of the Public Service Rearrangement and Transfer of Duties Act b , transfers from the Privy Council Office to the Treasury Board the control and supervision of that portion of the federal public administration in the Privy Council Office known as the Canadian Secretariat to the Canada-U.S. Regulatory Cooperation Council, effective April 1, 2016. a S.C. 2003, c. 22, s. 207 b R.S., c. P-34