GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Income Tax Conventions Implementation Act, 1996 — I-3.51 (a)
(a) subject to the provisions of the law of Ukraine regarding the elimination of tax payable in a territory outside Ukraine (which shall not affect the general principle hereof), Canadian tax payable under the laws of Canada and in accordance with this Convention, whether directly or by deduction, on profits, income or capital from sources within Canada shall be allowed as a credit against any Ukrainian tax computed by reference to the same profits, income or capital by reference to which the Ukrainian tax is computed;
Income Tax Conventions Implementation Act, 1996 — I-3.51 (b)
(b) the deduction in either case shall not exceed that part of 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.
Income Tax Conventions Implementation Act, 1996 — I-3.51 4
4 Where in accordance with any provision of the Convention income derived or capital owned 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 the remaining income or capital of such resident, take into account the exempted income or capital.
Income Tax Conventions Implementation Act, 1996 — I-3.51 1
1 Nationals of a Contracting State shall not be subjected in the other 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 that other State in the same circumstances are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, also apply to individuals who are not residents of one or both of the Contracting States.
Income Tax Conventions Implementation Act, 1996 — I-3.51 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.
Income Tax Conventions Implementation Act, 1996 — I-3.51 3
3 The taxation on a permanent establishment which a resident 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.
Income Tax Conventions Implementation Act, 1996 — I-3.51 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 which it grants to its own residents.
Income Tax Conventions Implementation Act, 1996 — I-3.51 5
5 The provisions of this Article shall apply to taxes covered by this Convention.
Income Tax Conventions Implementation Act, 1996 — I-3.51 1
1 Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, address to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national, 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 which gives rise to taxation not in accordance with the Convention.
Income Tax Conventions Implementation Act, 1996 — I-3.51 1
1 The competent authorities of the Contracting States shall exchange such information as is relevant for carrying out the provisions of this Convention or of the domestic laws (including the provisions for the prevention of fraud or fiscal avoidance) of the 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 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, 1996 — I-3.51 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 or the administrative practice of that or of the other Contracting State; (b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State; (c) to supply information which 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, 1996 — I-3.51 1
1 Nothing in this Convention shall affect the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or under the provisions of special agreements.
Income Tax Conventions Implementation Act, 1996 — I-3.51 2
2 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 he has an interest.
Income Tax Conventions Implementation Act, 1996 — I-3.51 3
3 For the purposes of 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, 1996 — I-3.51 1
1 Each of the Contracting States shall notify the other, through the diplomatic channel, of the completion of the procedures required by its domestic law for the bringing into force of this Convention. The Convention shall enter into force on the date of the later of these notifications and shall thereupon 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 sixtieth day following the day on 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 next following that in which the Convention enters into force; (b) in Ukraine: (i) in respect of taxes on dividends, interest or royalties for any payments made on or after the sixtieth day following the day on which the Convention enters into force, (ii) in respect of the tax on profit of enterprises for any taxation period beginning on or after the first day of January in the calendar year next following that in which the Convention enters into force, and (iii) in respect of the income tax on citizens for any payments made on or after the sixtieth day following the day on which the Convention enters into force.
Income Tax Conventions Implementation Act, 1996 — I-3.51 (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 sixtieth day following the day on 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 next following that in which the Convention enters into force;
Income Tax Conventions Implementation Act, 1996 — I-3.51 (i)
(i) in respect of tax withheld at the source on amounts paid or credited to non-residents on or after the sixtieth day following the day on which the Convention enters into force, and
Income Tax Conventions Implementation Act, 1996 — I-3.51 (ii)
(ii) in respect of other Canadian tax for taxation years beginning on or after the first day of January in the calendar year next following that in which the Convention enters into force;
Income Tax Conventions Implementation Act, 1996 — I-3.51 (b)
(b) in Ukraine: (i) in respect of taxes on dividends, interest or royalties for any payments made on or after the sixtieth day following the day on which the Convention enters into force, (ii) in respect of the tax on profit of enterprises for any taxation period beginning on or after the first day of January in the calendar year next following that in which the Convention enters into force, and (iii) in respect of the income tax on citizens for any payments made on or after the sixtieth day following the day on which the Convention enters into force.
Income Tax Conventions Implementation Act, 1996 — I-3.51 (i)
(i) in respect of taxes on dividends, interest or royalties for any payments made on or after the sixtieth day following the day on which the Convention enters into force,
Income Tax Conventions Implementation Act, 1996 — I-3.51 (ii)
(ii) in respect of the tax on profit of enterprises for any taxation period beginning on or after the first day of January in the calendar year next following that in which the Convention enters into force, and
Income Tax Conventions Implementation Act, 1996 — I-3.51 (iii)
(iii) in respect of the income tax on citizens for any payments made on or after the sixtieth day following the day on which the Convention enters into force.
Income Tax Conventions Implementation Act, 1996 — I-3.51 2
2 From the date of entry into force of this Convention the Agreement between the Government of Canada and the Government of the Union of Soviet Socialist Republics for the Avoidance of Double Taxation on Income signed at Moscow on the 13th day of June, 1985, shall, as between Canada and Ukraine, terminate. However, the provisions of the 1985 Agreement corresponding to those of this Convention shall continue to have effect until the provisions of this Convention take effect in accordance with the provisions of paragraph 1.
Income Tax Conventions Implementation Act, 1996 — I-3.51 (a)
This Convention shall remain in force until terminated by one of the Contracting States. Either Contracting State may terminate the Convention, through the diplomatic channel, by giving notice of termination at least six months before the end of any calendar year beginning after the expiry of five years from the date of entry into force of the Convention. 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 in the calendar year next following that in which the notice is given, and (ii) in respect of other Canadian tax for taxation years beginning on or after the first day of January in the calendar year next following that in which the notice is given; (b) in Ukraine: (i) in respect of taxes on dividends, interest or royalties for any payments made on or after the sixtieth day following the day on which the notice is given, (ii) in respect of the tax on profit of enterprises for any taxation period beginning on or after the first day of January in the calendar year next following that in which the notice is given, and (iii) in respect of the income tax on citizens for any payments made on or after the sixtieth day following the day on which the notice is given.
Income Tax Conventions Implementation Act, 1996 — I-3.51 (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 next following that in which the notice is given, and (ii) in respect of other Canadian tax for taxation years beginning on or after the first day of January in the calendar year next following that in which the notice is given;
Income Tax Conventions Implementation Act, 1996 — I-3.51 (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 next following that in which the notice is given, and
Income Tax Conventions Implementation Act, 1996 — I-3.51 (ii)
(ii) in respect of other Canadian tax for taxation years beginning on or after the first day of January in the calendar year next following that in which the notice is given;
Income Tax Conventions Implementation Act, 1996 — I-3.51 (b)
(b) in Ukraine: (i) in respect of taxes on dividends, interest or royalties for any payments made on or after the sixtieth day following the day on which the notice is given, (ii) in respect of the tax on profit of enterprises for any taxation period beginning on or after the first day of January in the calendar year next following that in which the notice is given, and (iii) in respect of the income tax on citizens for any payments made on or after the sixtieth day following the day on which the notice is given.
Income Tax Conventions Implementation Act, 1996 — I-3.51 (i)
(i) in respect of taxes on dividends, interest or royalties for any payments made on or after the sixtieth day following the day on which the notice is given,
Income Tax Conventions Implementation Act, 1996 — I-3.51 (ii)
(ii) in respect of the tax on profit of enterprises for any taxation period beginning on or after the first day of January in the calendar year next following that in which the notice is given, and
Income Tax Conventions Implementation Act, 1996 — I-3.51 (iii)
(iii) in respect of the income tax on citizens for any payments made on or after the sixtieth day following the day on which the notice is given.
Income Tax Conventions Implementation Act, 1996 — I-3.51
DONE in duplicate at Kyiv, this 4th day of March 1996, in the English, French and Ukrainian languages, each version being equally authentic. FOR THE GOVERNMENT OF CANADA: C. Westdal FOR THE GOVERNMENT OF UKRAINE: Petro Hermanchuk
Income Tax Conventions Implementation Act, 1997 — I-3.52
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, 1997 — I-3.52 1
Short title 1 This Act may be cited as the Income Tax Conventions Implementation Act, 1997 .
Income Tax Conventions Implementation Act, 1997 — I-3.52 2
Citation of Part 1 2 This Part may be cited as the Canada — Sweden Income Tax Convention Act, 1997 .
Income Tax Conventions Implementation Act, 1997 — I-3.52 3
Definition of Convention 3 In this Part, Convention means the Convention between the Government of Canada and the Government of Sweden set out in Schedule 1.
Income Tax Conventions Implementation Act, 1997 — I-3.52 4
Convention approved 4 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, 1997 — I-3.52 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 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, 1997 — I-3.52 6
Regulations 6 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, 1997 — I-3.52 Publication of notice
Publication of notice * 7 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. * [Note: Convention in force December 23, 1997, see Canada Gazette Part I, Volume 132, page 157.]
Income Tax Conventions Implementation Act, 1997 — I-3.52 8
Citation of Part 2 8 This Part may be cited as the Canada — Lithuania Income Tax Convention Act, 1997 .
Income Tax Conventions Implementation Act, 1997 — I-3.52 9
Definition of Convention 9 In this Part, Convention means the Convention between the Government of Canada and the Government of the Republic of Lithuania set out in Schedule 2.
Income Tax Conventions Implementation Act, 1997 — I-3.52 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, 1997 — I-3.52 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, 1997 — I-3.52 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, 1997 — I-3.52 Publication of notice
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. * [Note: Convention in force December 12, 1997, see Canada Gazette Part I, Volume 132, page 157.]
Income Tax Conventions Implementation Act, 1997 — I-3.52 14
Citation of Part 3 14 This Part may be cited as the Canada — Kazakhstan Income Tax Convention Act, 1997 .
Income Tax Conventions Implementation Act, 1997 — I-3.52 15
Definition of Convention 15 In this Part, Convention means the Convention between the Government of Canada and the Government of the Republic of Kazakhstan set out in Schedule 3, as amended by the Protocol set out in that Schedule.
Income Tax Conventions Implementation Act, 1997 — I-3.52 16
Convention approved 16 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, 1997 — I-3.52 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 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, 1997 — I-3.52 18
Regulations 18 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, 1997 — I-3.52 Publication of notice
Publication of notice * 19 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. * [Note: Convention in force March 30, 1998, see Canada Gazette Part I, Volume 132, page 1059.]
Income Tax Conventions Implementation Act, 1997 — I-3.52 20
Citation of Part 4 20 This Part may be cited as the Canada — Iceland Income Tax Convention Act, 1997 .
Income Tax Conventions Implementation Act, 1997 — I-3.52 21
Definition of Convention 21 In this Part, Convention means the Convention between the Government of Canada and the Government of the Republic of Iceland set out in Schedule 4.
Income Tax Conventions Implementation Act, 1997 — I-3.52 22
Convention approved 22 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, 1997 — I-3.52 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 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, 1997 — I-3.52 24
Regulations 24 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, 1997 — I-3.52 Publication of notice
Publication of notice * 25 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. * [Note: Convention in force January 30, 1998, see Canada Gazette Part I, Volume 132, page 157.]
Income Tax Conventions Implementation Act, 1997 — I-3.52 26
Citation of Part 5 26 This Part may be cited as the Canada — Denmark Income Tax Convention Act, 1997 .
Income Tax Conventions Implementation Act, 1997 — I-3.52 27
Definition of Convention 27 In this Part, Convention means the Convention between the Government of Canada and the Government of the Kingdom of Denmark set out in Schedule 5, as amended by the Protocol set out in that Schedule.
Income Tax Conventions Implementation Act, 1997 — I-3.52 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, 1997 — I-3.52 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, 1997 — I-3.52 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.