GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 4
4 The term interest as used in this Article means income from debt-claims of every kind, whether or not secured by mortgage, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures, as well as income which is subjected to the same taxation treatment as income from money lent by the laws of the State in which the income arises. However, the term interest does not include income dealt with in Article 8 or in Article 10.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 5
5 The provisions of paragraph 2 shall not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the debt-claim in respect of which the interest is paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall supply.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 6
6 Interest shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in the State in which the permanent establishment or fixed base is situated.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 7
7 Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt-claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the royalties the tax so charged shall not exceed: (a) 3 per cent of the gross amount paid for the use of, or the right to use, news; (b) 5 per cent of the gross amount paid for the use of, or the right to use, copyright of literary, dramatic, musical or other artistic work (but not including royalties in respect of motion picture films and works on film or videotape or other means of reproduction for use in connection with television); (c) 10 per cent of the gross amount paid for the use of, or the right to use, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial or scientific equipment, or for information concerning industrial or scientific experience, and includes payments for the rendering of technical assistance; and (d) 15 per cent of the gross amount of the royalties in all other cases.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
(a) 3 per cent of the gross amount paid for the use of, or the right to use, news;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (b)
(b) 5 per cent of the gross amount paid for the use of, or the right to use, copyright of literary, dramatic, musical or other artistic work (but not including royalties in respect of motion picture films and works on film or videotape or other means of reproduction for use in connection with television);
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (c)
(c) 10 per cent of the gross amount paid for the use of, or the right to use, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial or scientific equipment, or for information concerning industrial or scientific experience, and includes payments for the rendering of technical assistance; and
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (d)
(d) 15 per cent of the gross amount of the royalties in all other cases.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 3
3 The term royalties as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, news, any copyright of literary, dramatic, musical or other artistic work, any patent, trade mark, design or model, plan, secret formula or process or other intangible property, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience, and includes payments for the rendering of technical assistance and payments of any kind in respect of motion picture films and works on film, videotape or other means of reproduction for use in connection with television.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 4
4 The provisions of paragraph 2 shall not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 5
5 Royalties shall be deemed to arise in a Contracting State when the payer is that State itself, a political subdivision, a local authority or a resident of that State. Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanent establishment or fixed base is situated.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 6
6 Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 Gains derived by a resident of a Contracting State from the alienation of property situated in the other Contracting State may be taxed in that other State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 Notwithstanding the provisions of paragraph 1, gains from the alienation of ships or aircraft operated in international traffic by an enterprise of a Contracting State or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 Income derived by an individual who is a resident of a Contracting State in respect of professional services or other activities of an independent character performed in the other Contracting State may be taxed in that other State but the tax so charged shall not exceed 10 per cent of the gross amount of that income unless he has a fixed base regularly available to him in that other State for the purpose of performing his activities. If he has or had such a fixed base, the income may be taxed in the other State in accordance with the law of that State, but only so much of it as is attributable to that fixed base.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 The term professional services includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants but it does not include technical services dealt with in Article 12.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the calendar year concerned; and (b) the remuneration is paid by, or on behalf of, a person who is not a resident of the other State; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the person has in the other State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the calendar year concerned; and
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (b)
(b) the remuneration is paid by, or on behalf of, a person who is not a resident of the other State; and
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (c)
(c) the remuneration is not borne by a permanent establishment or a fixed base which the person has in the other State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 3
3 Notwithstanding the preceding provisions of this Article, remuneration 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-Argentina Income Tax Convention Act, 1994 — C-0.6
Directors’ fees and other similar payments derived by a resident of a Contracting State in his 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-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 Notwithstanding the provisions of Articles 7, 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 sportsman, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 Where income in respect of personal activities exercised by an entertainer or a sportsman in his capacity as such accrues not to the entertainer or sportsman himself 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 sportsman are exercised.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 3
3 The provisions of paragraphs 1 and 2 shall not apply to income derived from activities performed in a Contracting State by a resident of the other Contracting State in the context of a visit in the first-mentioned State of a non-profit organization of the other State provided that the visit is substantially supported by public funds.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 Pensions and annuities (including “jubilaciones” in the case of Argentina) arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 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 law of that State. However, in the case of periodic pension payments, 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 him in the year, if he were resident in the Contracting State in which the payment arises.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
(a) 15 per cent of the gross amount of the payment, and
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (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 him in the year, if he were resident in the Contracting State in which the payment arises.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 3
3 Annuities 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 law of that State; but the tax so charged shall not exceed 15 per cent of the portion thereof that is subject to tax in that State. However, this limitation does not apply to lump-sum payments arising on the surrender, cancellation, redemption, sale or other alienation of an annuity, or to payments of any kind under an annuity contract the cost of which was deductible, in whole or in part, in computing the income of any person who acquired the contract.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 4
4 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; and (b) alimony and other similar payments arising in a Contracting State and paid to a resident of the other Contracting State who is the beneficial owner thereof, shall be taxable only in that other State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (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; and
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (b)
(b) alimony and other similar payments arising in a Contracting State and paid to a resident of the other Contracting State who is the beneficial owner thereof, shall be taxable only in that other State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
(a) Salaries, wages and similar remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority in any other State, shall be taxable only in the first-mentioned State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (b)
(b) However, such salaries, wages and 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-Argentina Income Tax Convention Act, 1994 — C-0.6 (ii)
(ii) did not become a resident of that State solely for the purpose of rendering the services.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 The provisions of paragraph 1 shall not apply to remuneration in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6
Payments which a student, apprentice or business trainee 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 his education or training receives for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such payments arise from sources outside that State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6
Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention may be taxed in that State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 Capital represented by property owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other State.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 Notwithstanding the provisions of paragraph 1, 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-Argentina Income Tax Convention Act, 1994 — C-0.6 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 Argentina on profits, income or gains arising in Argentina 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 taxation of income from a foreign affiliate and to any subsequent modification of those provisions — which shall not affect the general principle hereof — for the purpose of computing Canadian tax, a company which is a resident of Canada shall be allowed to deduct in computing its taxable income any dividend received by it out of the exempt surplus of a foreign affiliate which is a resident of Argentina.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (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 Argentina on profits, income or gains arising in Argentina shall be deducted from any Canadian tax payable in respect of such profits, income or gains;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (b)
(b) subject to the existing provisions of the law of Canada regarding the taxation of income from a foreign affiliate and to any subsequent modification of those provisions — which shall not affect the general principle hereof — for the purpose of computing Canadian tax, a company which is a resident of Canada shall be allowed to deduct in computing its taxable income any dividend received by it out of the exempt surplus of a foreign affiliate which is a resident of Argentina.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 For the purpose of subparagraph (a) of paragraph 1, tax payable in Argentina by a company engaged primarily in the manufacturing or natural resources sector which is a resident of Canada in respect of: (a) interest, other than interest which is exempted in Argentina in accordance with paragraph 3 of Article 11, or (b) industrial royalties referred to in paragraph 3 of Article 12 paid by a company engaged primarily in the same sector which is a resident of Argentina shall be deemed to have been paid at the rate of 12.5 per cent in the case of interest and at the rate of 15 per cent in the case of royalties. The provisions of this paragraph shall apply for the first five years for which the Convention is effective, but the competent authorities of the Contracting States may consult with each other to determine whether this period shall be extended.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
(a) interest, other than interest which is exempted in Argentina in accordance with paragraph 3 of Article 11, or
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (b)
(b) industrial royalties referred to in paragraph 3 of Article 12
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6
paid by a company engaged primarily in the same sector which is a resident of Argentina shall be deemed to have been paid at the rate of 12.5 per cent in the case of interest and at the rate of 15 per cent in the case of royalties. The provisions of this paragraph shall apply for the first five years for which the Convention is effective, but the competent authorities of the Contracting States may consult with each other to determine whether this period shall be extended.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 3
3 For the purposes of subparagraph (a) of paragraph 1, tax payable in Argentina by a company which is a resident of Canada in respect of profits attributable to manufacturing activities or to the exploration or exploitation of natural resources carried on by it in Argentina shall be deemed to include any amount which would have been payable thereon as Argentine tax for any year but for an exemption from, or reduction of, tax granted for that year or any part thereof under specific provisions of Argentine legislation that the competent authority of Canada agrees should be covered by this provision, and only to the extent that the said provisions have the effect of exempting or relieving a source of income for a period not in excess of ten years.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 4
4 In the case where a resident of Argentina derives income from sources in Canada, the resident shall be allowed a credit in the determination of the Argentine tax for the tax paid on such income to Canada. However, the tax credit shall not exceed the amount of the Argentine tax on such income determined in accordance with its internal law.