GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Income Tax Conventions Implementation Act, 1995 — I-3.5 3
3 This Convention shall not apply to international organizations, to organs or officials thereof and to persons who are members of a diplomatic mission, consular post or permanent mission of a third State or group of States, being present in a Contracting State and who are not liable in either Contracting State to the same obligations in relation to tax on their total income as are residents thereof.
Income Tax Conventions Implementation Act, 1995 — I-3.5 1
1 The provisions of this Convention shall not be construed to restrict in any manner any exemption, allowance, credit or other deduction accorded by the laws of a Contracting State in the determination of the tax imposed by that State.
Income Tax Conventions Implementation Act, 1995 — I-3.5 2
2 Nothing in this Convention shall be construed as preventing a Contracting State from imposing a tax on amounts included in the income of a resident of that State with respect to a partnership, trust, or controlled foreign affiliate within the meaning of the Canadian Income Tax Act , in which he has an interest.
Income Tax Conventions Implementation Act, 1995 — I-3.5 3
3 This 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, 1995 — I-3.5 4
4 With respect to paragraph 3 of Article XXII of the General Agreement on Trade in Services, the Contracting States agree that, notwithstanding that paragraph, any dispute between them as to whether a measure relating to a tax to which any provision of this Convention applies falls within the scope of this Convention may be brought before the Council for Trade in Services, as provided by that paragraph, only with the consent of both Contracting States.
Income Tax Conventions Implementation Act, 1995 — I-3.5 5
5 Where in accordance with any provision of this Convention income derived by a resident of a Contracting State is exempt from tax in that State, such State may nevertheless, in calculating the amount of tax on other income, take into account the exempted income.
Income Tax Conventions Implementation Act, 1995 — I-3.5 1
1 Each of the Contracting States shall take all measures necessary to give this Convention the force of law within its jurisdiction and each shall notify the other of the completion of such measures. This Convention shall enter into force on the date on which the later notification is made and shall thereupon have effect (a) in respect of tax withheld at the source on amounts paid or credited to non-residents on or after the first day of the second month following the date on which this Convention enters into force; and (b) in respect of other taxes for taxation years or years of income beginning on or after the first day of January in the calendar year in which this Convention enters into force.
Income Tax Conventions Implementation Act, 1995 — I-3.5 (a)
(a) in respect of tax withheld at the source on amounts paid or credited to non-residents on or after the first day of the second month following the date on which this Convention enters into force; and
Income Tax Conventions Implementation Act, 1995 — I-3.5 (b)
(b) in respect of other taxes for taxation years or years of income beginning on or after the first day of January in the calendar year in which this Convention enters into force.
Income Tax Conventions Implementation Act, 1995 — I-3.5 2
2 The provisions of the Agreement between the Government of Canada and the Government of Trinidad and Tobago with respect to taxes on income, for the avoidance of double taxation, the prevention of fiscal evasion, and encouragement of international trade and investment signed at Washington on September 28th, 1966, shall cease to have effect with respect to taxes to which this Convention applies in accordance with the provisions of paragraph 1. Where, however, any greater relief from tax would have been afforded by any provision of that Agreement than is due under this Convention, any such provision as aforesaid shall continue to have effect with respect to taxes referred to in subparagraph (b) of paragraph 1 (a) in Canada, for any taxation year, (b) in Trinidad and Tobago, for any year of income, beginning before the entry into force of this Convention.
Income Tax Conventions Implementation Act, 1995 — I-3.5 (b)
(b) in Trinidad and Tobago, for any year of income, beginning before the entry into force of this Convention.
Income Tax Conventions Implementation Act, 1995 — I-3.5
beginning before the entry into force of this Convention.
Income Tax Conventions Implementation Act, 1995 — I-3.5 (a)
This Convention shall continue in effect indefinitely but either Contracting State may terminate this Convention by giving to the other Contracting State at least six months prior notice of termination in writing through diplomatic channels; in such event, this Convention shall cease to have effect (a) 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 next following the expiration of the six-month period referred to above; and (b) in respect of other taxes for taxation years or income years beginning on or after the first day of January in the calendar year next following the expiration of the six-month notice referred to above.
Income Tax Conventions Implementation Act, 1995 — I-3.5 (a)
(a) 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 next following the expiration of the six-month period referred to above; and
Income Tax Conventions Implementation Act, 1995 — I-3.5 (b)
(b) in respect of other taxes for taxation years or income years beginning on or after the first day of January in the calendar year next following the expiration of the six-month notice referred to above.
Income Tax Conventions Implementation Act, 1995 — I-3.5
DONE in duplicate at Toronto, this 11th day of September 1995, in the English and French languages, each version being equally authentic. FOR THE GOVERNMENT OF CANADA: Roy MacLaren FOR THE GOVERNMENT OF THE REPUBLIC OF TRINIDAD AND TOBAGO: Gordon Draper
Income Tax Conventions Implementation Act, 1995 — I-3.5
FOR THE GOVERNMENT OF THE REPUBLIC OF TRINIDAD AND TOBAGO:
Income Tax Conventions Implementation Act, 1996 — I-3.51
Her Majesty, by and with the advice and consent of the Senate and House of Commons of Canada, enacts as follows:
Income Tax Conventions Implementation Act, 1996 — I-3.51 1
Short title 1 This Act may be cited as the Income Tax Conventions Implementation Act, 1996 .
Income Tax Conventions Implementation Act, 1996 — I-3.51 2
Citation of Part I 2 This Part may be cited as the Canada — Russia Income Tax Agreement Act, 1996 .
Income Tax Conventions Implementation Act, 1996 — I-3.51 3
Definition of “Agreement” 3 In this Part, Agreement means the Agreement between the Government of Canada and the Government of the Russian Federation set out in Schedule I, as amended by the Protocol set out in that Schedule.
Income Tax Conventions Implementation Act, 1996 — I-3.51 4
Agreement approved 4 The Agreement is approved and has the force of law in Canada during the period that the Agreement, by its terms, is in force.
Income Tax Conventions Implementation Act, 1996 — I-3.51 5
Inconsistent laws — general rule 5 (1) Subject to subsection (2), in the event of any inconsistency between the provisions of this Part or the Agreement and the provisions of any other law, the provisions of this Part and the Agreement prevail to the extent of the inconsistency. Inconsistent laws — exception (2) In the event of any inconsistency between the provisions of the Agreement and the provisions of the Income Tax Conventions Interpretation Act , the provisions of that Act prevail to the extent of the inconsistency.
Income Tax Conventions Implementation Act, 1996 — I-3.51 6
Regulations 6 The Minister of National Revenue may make any regulations that are necessary for carrying out the Agreement or for giving effect to any of its provisions.
Income Tax Conventions Implementation Act, 1996 — I-3.51 7
Publication of notice 7 The Minister of Finance shall cause a notice of the day on which the Agreement enters into force and of the day on which it ceases to have effect to be published in the Canada Gazette within sixty days after its entry into force or termination.
Income Tax Conventions Implementation Act, 1996 — I-3.51 8
Citation of Part II 8 This Part may be cited as the Canada — South Africa Income Tax Convention Act, 1996 .
Income Tax Conventions Implementation Act, 1996 — I-3.51 9
Definition of “Convention” 9 In this Part, Convention means the Convention between the Government of Canada and the Government of the Republic of South Africa set out in Schedule II.
Income Tax Conventions Implementation Act, 1996 — I-3.51 10
Convention approved 10 The Convention is approved and has the force of law in Canada during the period that the Convention, by its terms, is in force.
Income Tax Conventions Implementation Act, 1996 — I-3.51 11
Inconsistent laws — general rule 11 (1) Subject to subsection (2), in the event of any inconsistency between the provisions of this Part or the Convention and the provisions of any other law, the provisions of this Part and the Convention prevail to the extent of the inconsistency. Inconsistent laws — exception (2) In the event of any inconsistency between the provisions of the Convention and the provisions of the Income Tax Conventions Interpretation Act , the provisions of that Act prevail to the extent of the inconsistency.
Income Tax Conventions Implementation Act, 1996 — I-3.51 12
Regulations 12 The Minister of National Revenue may make any regulations that are necessary for carrying out the Convention or for giving effect to any of its provisions.
Income Tax Conventions Implementation Act, 1996 — I-3.51 13
Publication of notice 13 The Minister of Finance shall cause a notice of the day on which the Convention enters into force and of the day on which it ceases to have effect to be published in the Canada Gazette within sixty days after its entry into force or termination.
Income Tax Conventions Implementation Act, 1996 — I-3.51 14
Citation of Part III 14 This Part may be cited as the Canada — Tanzania Income Tax Agreement Act, 1996 .
Income Tax Conventions Implementation Act, 1996 — I-3.51 15
Definition of “Agreement” 15 In this Part, Agreement means the Agreement between the Government of Canada and the Government of the United Republic of Tanzania set out in Schedule III.
Income Tax Conventions Implementation Act, 1996 — I-3.51 16
Agreement approved 16 The Agreement is approved and has the force of law in Canada during the period that the Agreement, by its terms, is in force.
Income Tax Conventions Implementation Act, 1996 — I-3.51 17
Inconsistent laws — general rule 17 (1) Subject to subsection (2), in the event of any inconsistency between the provisions of this Part or the Agreement and the provisions of any other law, the provisions of this Part and the Agreement prevail to the extent of the inconsistency. Inconsistent laws — exception (2) In the event of any inconsistency between the provisions of the Agreement and the provisions of the Income Tax Conventions Interpretation Act , the provisions of that Act prevail to the extent of the inconsistency.
Income Tax Conventions Implementation Act, 1996 — I-3.51 18
Regulations 18 The Minister of National Revenue may make any regulations that are necessary for carrying out the Agreement or for giving effect to any of its provisions.
Income Tax Conventions Implementation Act, 1996 — I-3.51 19
Publication of notice 19 The Minister of Finance shall cause a notice of the day on which the Agreement enters into force and of the day on which it ceases to have effect to be published in the Canada Gazette within sixty days after its entry into force or termination.
Income Tax Conventions Implementation Act, 1996 — I-3.51 20
Citation of Part IV 20 This Part may be cited as the Canada — India Income Tax Agreement Act, 1996 .
Income Tax Conventions Implementation Act, 1996 — I-3.51 21
Definition of “Agreement” 21 In this Part, Agreement means the Agreement between the Government of Canada and the Government of the Republic of India set out in Schedule IV, as amended by the Protocol set out in that Schedule.
Income Tax Conventions Implementation Act, 1996 — I-3.51 22
Agreement approved 22 The Agreement is approved and has the force of law in Canada during the period that the Agreement, by its terms, is in force.
Income Tax Conventions Implementation Act, 1996 — I-3.51 23
Inconsistent laws — general rule 23 (1) Subject to subsection (2), in the event of any inconsistency between the provisions of this Part or the Agreement and the provisions of any other law, the provisions of this Part and the Agreement prevail to the extent of the inconsistency. Inconsistent laws — exception (2) In the event of any inconsistency between the provisions of the Agreement and the provisions of the Income Tax Conventions Interpretation Act , the provisions of that Act prevail to the extent of the inconsistency.
Income Tax Conventions Implementation Act, 1996 — I-3.51 24
Regulations 24 The Minister of National Revenue may make any regulations that are necessary for carrying out the Agreement or for giving effect to any of its provisions.
Income Tax Conventions Implementation Act, 1996 — I-3.51 25
Publication of notice 25 The Minister of Finance shall cause a notice of the day on which the Agreement enters into force and of the day on which it ceases to have effect to be published in the Canada Gazette within sixty days after its entry into force or termination.
Income Tax Conventions Implementation Act, 1996 — I-3.51 26
Citation of Part V 26 This Part may be cited as the Canada — Ukraine Income Tax Convention Act, 1996 .
Income Tax Conventions Implementation Act, 1996 — I-3.51 27
Definition of “Convention” 27 In this Part, Convention means the Convention between the Government of Canada and the Government of Ukraine set out in Schedule V.
Income Tax Conventions Implementation Act, 1996 — I-3.51 28
Convention approved 28 The Convention is approved and has the force of law in Canada during the period that the Convention, by its terms, is in force.
Income Tax Conventions Implementation Act, 1996 — I-3.51 29
Inconsistent laws — general rule 29 (1) Subject to subsection (2), in the event of any inconsistency between the provisions of this Part or the Convention and the provisions of any other law, the provisions of this Part and the Convention prevail to the extent of the inconsistency. Inconsistent laws — exception (2) In the event of any inconsistency between the provisions of the Convention and the provisions of the Income Tax Conventions Interpretation Act , the provisions of that Act prevail to the extent of the inconsistency.
Income Tax Conventions Implementation Act, 1996 — I-3.51 30
Regulations 30 The Minister of National Revenue may make any regulations that are necessary for carrying out the Convention or for giving effect to any of its provisions.
Income Tax Conventions Implementation Act, 1996 — I-3.51 31
Publication of notice 31 The Minister of Finance shall cause a notice of the day on which the Convention enters into force and of the day on which it ceases to have effect to be published in the Canada Gazette within sixty days after its entry into force or termination.
Income Tax Conventions Implementation Act, 1996 — I-3.51
The Government of Canada and the Government of the Russian Federation, desiring to conclude an Agreement 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, 1996 — I-3.51
This Agreement shall apply to persons who are residents of one or both of the Contracting States.
Income Tax Conventions Implementation Act, 1996 — I-3.51 1
1 This Agreement shall apply to the following taxes on income and on capital, irrespective of the manner in which they are levied: (a) in the case of Canada, the taxes imposed by the Government of Canada under the Income Tax Act (hereinafter referred to as “Canadian tax”); (b) in the case of the Russian Federation, the taxes imposed under the following Acts: (i) “Tax on profits of enterprises and organizations”, (ii) “Income tax on individuals”, (iii) “Tax on capital of enterprises”, and (iv) “Tax on capital of individuals”, including taxes of a similar nature levied by state authorities of the Russian Federation (hereinafter referred to as “Russian tax”).
Income Tax Conventions Implementation Act, 1996 — I-3.51 (a)
(a) in the case of Canada, the taxes imposed by the Government of Canada under the Income Tax Act (hereinafter referred to as “Canadian tax”);
Income Tax Conventions Implementation Act, 1996 — I-3.51 (b)
(b) in the case of the Russian Federation, the taxes imposed under the following Acts: (i) “Tax on profits of enterprises and organizations”, (ii) “Income tax on individuals”, (iii) “Tax on capital of enterprises”, and (iv) “Tax on capital of individuals”, including taxes of a similar nature levied by state authorities of the Russian Federation (hereinafter referred to as “Russian tax”).
Income Tax Conventions Implementation Act, 1996 — I-3.51 (i)
(i) “Tax on profits of enterprises and organizations”,
Income Tax Conventions Implementation Act, 1996 — I-3.51 (iii)
(iii) “Tax on capital of enterprises”, and
Income Tax Conventions Implementation Act, 1996 — I-3.51
including taxes of a similar nature levied by state authorities of the Russian Federation (hereinafter referred to as “Russian tax”).
Income Tax Conventions Implementation Act, 1996 — I-3.51 2
2 The Agreement shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Agreement in addition to, or in place of, the taxes referred to in paragraph 1. 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, 1996 — I-3.51 1
1 In this Agreement, unless the context otherwise requires: (a) the term “Canada”, used in a geographical sense, means the territory of Canada, including: (i) 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) the seas and airspace above every area referred to in subparagraph (i) in respect of any activity carried on in connection with the exploration for or the exploitation of the natural resources referred to therein; (b) the term “Russian Federation - Russia”, used in a geographical sense, means its territory, including its internal bodies of water, territorial waters in the sea and the air space above them, as well as the continental shelf and the exclusive economic zone, where the Russian Federation has sovereign rights and exercises jurisdiction as defined by federal law and the rules of international law. The names “Russian Federation” and “Russia” are synonymous; (c) the terms “a Contracting State” and “the other Contracting State” mean, as the context requires, Canada or the Russian Federation; (d) the term “person” includes an individual, a trust, a company, a partnership and any other body of persons; (e) the term “company” means any body corporate or any entity which is treated as a body corporate for tax purposes; (f) the term “competent authority” means: (i) in the case of Canada, the Minister of National Revenue or his authorized representative, (ii) in the case of the Russian Federation, the Ministry of Finance or its authorized representative; (g) the term “international traffic” means any transport by a ship or aircraft except when the ship or aircraft is operated solely between places in a Contracting State.
Income Tax Conventions Implementation Act, 1996 — I-3.51 (a)
(a) the term “Canada”, used in a geographical sense, means the territory of Canada, including: (i) 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) the seas and airspace above every area referred to in subparagraph (i) in respect of any activity carried on in connection with the exploration for or the exploitation of the natural resources referred to therein;
Income Tax Conventions Implementation Act, 1996 — I-3.51 (i)
(i) 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, 1996 — I-3.51 (ii)
(ii) the seas and airspace above every area referred to in subparagraph (i) in respect of any activity carried on in connection with the exploration for or the exploitation of the natural resources referred to therein;
Income Tax Conventions Implementation Act, 1996 — I-3.51 (b)
(b) the term “Russian Federation - Russia”, used in a geographical sense, means its territory, including its internal bodies of water, territorial waters in the sea and the air space above them, as well as the continental shelf and the exclusive economic zone, where the Russian Federation has sovereign rights and exercises jurisdiction as defined by federal law and the rules of international law. The names “Russian Federation” and “Russia” are synonymous;
Income Tax Conventions Implementation Act, 1996 — I-3.51 (c)
(c) the terms “a Contracting State” and “the other Contracting State” mean, as the context requires, Canada or the Russian Federation;
Income Tax Conventions Implementation Act, 1996 — I-3.51 (d)
(d) the term “person” includes an individual, a trust, a company, a partnership and any other body of persons;
Income Tax Conventions Implementation Act, 1996 — I-3.51 (e)
(e) the term “company” means any body corporate or any entity which is treated as a body corporate for tax purposes;
Income Tax Conventions Implementation Act, 1996 — I-3.51 (f)
(f) the term “competent authority” means: (i) in the case of Canada, the Minister of National Revenue or his authorized representative, (ii) in the case of the Russian Federation, the Ministry of Finance or its authorized representative;
Income Tax Conventions Implementation Act, 1996 — I-3.51 (i)
(i) in the case of Canada, the Minister of National Revenue or his authorized representative,
Income Tax Conventions Implementation Act, 1996 — I-3.51 (ii)
(ii) in the case of the Russian Federation, the Ministry of Finance or its authorized representative;
Income Tax Conventions Implementation Act, 1996 — I-3.51 (g)
(g) the term “international traffic” means any transport by a ship or aircraft except when the ship or aircraft is operated solely between places in a Contracting State.
Income Tax Conventions Implementation Act, 1996 — I-3.51 2
2 As regards the application of the Agreement by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which the Agreement applies.
Income Tax Conventions Implementation Act, 1996 — I-3.51 1
1 For the purposes of this Agreement, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature.