GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Canada–Israel Tax Convention Act, 2016 — C-6.42 5
5 The competent authorities of the Contracting States may communicate with each other directly for the purpose of applying this Convention.
Canada–Israel Tax Convention Act, 2016 — C-6.42 1
1 The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Convention or to the administration or enforcement of the domestic laws concerning taxes covered by this Convention imposed on behalf of the Contracting States, insofar as the taxation thereunder is not contrary to this Convention. The exchange of information is not restricted by Article 1 (Persons Covered).
Canada–Israel Tax Convention Act, 2016 — C-6.42 2
2 Any information received under paragraph 1 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) concerned with the assessment or collection of, the enforcement or prosecution in respect of, the determination of appeals in relation to taxes of every kind and description, or the oversight of the above. 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. Notwithstanding the foregoing, information received by a Contracting State may be used for other purposes when such information may be used for such other purposes under the laws of both States and the competent authority of the supplying State authorizes such use.
Canada–Israel Tax Convention Act, 2016 — C-6.42 3
3 In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting State the obligation: (a) to carry out administrative measures at variance with the laws and 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 ).
Canada–Israel Tax Convention Act, 2016 — C-6.42 (a)
(a) to carry out administrative measures at variance with the laws and the administrative practice of that or of the other Contracting State;
Canada–Israel Tax Convention Act, 2016 — C-6.42 (b)
(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;
Canada–Israel Tax Convention Act, 2016 — C-6.42 (c)
(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 ).
Canada–Israel Tax Convention Act, 2016 — C-6.42 4
4 If information is requested by a Contracting State in accordance with this Article, the other Contracting State shall use its information gathering measures to obtain the requested information, even though that other State may not need such information for its own tax purposes. The obligation contained in the preceding sentence is subject to the limitations of paragraph 3 but in no case shall such limitations be construed to permit a Contracting State to decline to supply information solely because it has no domestic interest in such information.
Canada–Israel Tax Convention Act, 2016 — C-6.42 5
5 In no case shall the provisions of paragraph 3 be construed to permit a Contracting State to decline to supply information solely because the information is held by a bank, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because the information relates to ownership interests in a person.
Canada–Israel Tax Convention Act, 2016 — C-6.42
Nothing in this Convention shall prevent a Contracting State from applying any provision of its laws which are designed to prevent avoidance or evasion of taxes.
Canada–Israel Tax Convention Act, 2016 — C-6.42 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.
Canada–Israel Tax Convention Act, 2016 — C-6.42 2
2 Notwithstanding the provisions of Article 4 (Resident), an individual who is a member of a diplomatic mission, consular post or permanent mission of a Contracting State which is situated in the other Contracting State or in a third State shall be deemed for the purposes of this Convention to be a resident only of the sending State if that individual is liable in the sending State to the same obligations in relation to tax on total income as are residents of that sending State.
Canada–Israel Tax Convention Act, 2016 — C-6.42 1
1 This Convention shall not affect the taxation by a Contracting State of its residents (as determined under Article 4 (Resident)). However, nothing in this paragraph shall affect the obligations of a Contracting State under paragraphs 2 and 3 of Article 9 (Associated Enterprises), paragraph 6 of Article 13 (Capital Gains), paragraph 4 of Article 17 (Pensions and Annuities), Article 18 (Government Service), Article 21 (Elimination of Double Taxation), Article 22 (Non-Discrimination) and paragraph 3 of Article 23 (Mutual Agreement Procedure).
Canada–Israel Tax Convention Act, 2016 — C-6.42 2
2 Nothing in this Convention shall prevent a Contracting State from applying the provisions of its laws relating to thin capitalization.
Canada–Israel Tax Convention Act, 2016 — C-6.42 3
3 For the purposes of paragraph 3 of Article XXII (Consultation) of the General Agreement on Trade in Services of the Agreement Establishing the World Trade Organization , done at Marrakesh on 15 April 1994, the Contracting States agree that, notwithstanding that paragraph, any dispute between them as to whether a measure 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. Any doubt as to the interpretation of this paragraph shall be resolved under paragraph 4 of Article 23 (Mutual Agreement Procedure) or, failing agreement under that procedure, pursuant to any other procedure agreed to by both Contracting States.
Canada–Israel Tax Convention Act, 2016 — C-6.42 1
1 Each of the Contracting States shall notify the other Contracting State in writing, through diplomatic channels, of the completion of the procedures required by its law for the bringing into force of this Convention. This Convention shall enter into force on the date of the later of these notifications and its provisions shall have effect: (a) in respect of taxes withheld at source, on amounts paid or credited to non-residents, on or after the first day of January of the calendar year following that in which this Convention enters into force; and (b) in respect of other taxes, for taxation years beginning on or after the first day of January of the calendar year following that in which this Convention enters into force.
Canada–Israel Tax Convention Act, 2016 — C-6.42 (a)
(a) in respect of taxes withheld at source, on amounts paid or credited to non-residents, on or after the first day of January of the calendar year following that in which this Convention enters into force; and
Canada–Israel Tax Convention Act, 2016 — C-6.42 (b)
(b) in respect of other taxes, for taxation years beginning on or after the first day of January of the calendar year following that in which this Convention enters into force.
Canada–Israel Tax Convention Act, 2016 — C-6.42 2
2 The Convention between Canada and the State of Israel for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital, done at Ottawa on 21 July 1975 (referred to herein as the “ 1975 Convention ”) shall cease to have effect from the dates on which this Convention becomes effective in accordance with paragraph 1.
Canada–Israel Tax Convention Act, 2016 — C-6.42 3
3 The 1975 Convention shall terminate on the last date on which it has effect in accordance with paragraph 2.
Canada–Israel Tax Convention Act, 2016 — C-6.42 4
4 Notwithstanding the provisions of this Article, the provisions of Article 23 (Mutual Agreement Procedure) and Article 24 (Exchange of Information) of this Convention shall have effect from the date of entry into force of this Convention, without regard to the taxable period to which the matter relates.
Canada–Israel Tax Convention Act, 2016 — C-6.42 1
1 This Convention shall continue in effect until terminated by a Contracting State. Either Contracting State may terminate this Convention, through diplomatic channels, by giving a written notice of termination at least six months before the end of any calendar year beginning on or after the expiration of a period of five years from the date of its entry into force. In such event, this Convention shall cease to have effect: (a) in respect of taxes withheld at source, on amounts paid or credited to non-residents, on or after the first day of January of the calendar year following that in which the notice has been given; and (b) in respect of other taxes, for taxation years beginning on or after the first day of January of the calendar year following that in which the notice has been given.
Canada–Israel Tax Convention Act, 2016 — C-6.42 (a)
(a) in respect of taxes withheld at source, on amounts paid or credited to non-residents, on or after the first day of January of the calendar year following that in which the notice has been given; and
Canada–Israel Tax Convention Act, 2016 — C-6.42 (b)
(b) in respect of other taxes, for taxation years beginning on or after the first day of January of the calendar year following that in which the notice has been given.
Canada–Israel Tax Convention Act, 2016 — C-6.42 2
2 This Convention shall terminate on the last date on which it has effect in accordance with paragraph 1, unless the Contracting States agree otherwise.
Canada–Israel Tax Convention Act, 2016 — C-6.42
IN WITNESS WHEREOF the undersigned, duly authorized to that effect, have signed this Convention.
Canada–Israel Tax Convention Act, 2016 — C-6.42
DONE in duplicate at New York, this 21st day of September 2016, which corresponds to the 18th day of Elul 5776 of the Hebrew Calendar, in the English, French and Hebrew languages, each version being equally authentic.
Canada–Israel Tax Convention Act, 2016 — C-6.42
FOR THE GOVERNMENT OF CANADA Stéphane Dion
Canada–Israel Tax Convention Act, 2016 — C-6.42
FOR THE GOVERNMENT OF THE STATE OF ISRAEL Moshe Kahlon
Canada–Israel Tax Convention Act, 2016 — C-6.42
At the time of signing of the Convention Between the Government of Canada and the Government of the State of Israel for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (the “ Convention ”), the Government of Canada and the Government of the State of Israel have agreed upon the following provisions which shall be an integral part of this Convention.
Canada–Israel Tax Convention Act, 2016 — C-6.42 1
1 With reference to the Convention: It is understood that 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.
Canada–Israel Tax Convention Act, 2016 — C-6.42
It is understood that 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.
Canada–Israel Tax Convention Act, 2016 — C-6.42 2
2 With reference to Article 2 (Taxes Covered) of the Convention: It is understood that the taxes described in clause 3(a)(i) include taxes imposed under the Petroleum Profits Taxation Law 5771-2011 .
Canada–Israel Tax Convention Act, 2016 — C-6.42
It is understood that the taxes described in clause 3(a)(i) include taxes imposed under the Petroleum Profits Taxation Law 5771-2011 .
Canada–Israel Tax Convention Act, 2016 — C-6.42 3
3 With reference to paragraph 1 of Article 4 (Resident) of the Convention: (a) It is understood that the term “ agency ”, in relation to a State or any political subdivision or local authority thereof, includes a body empowered to perform functions or duties of a governmental nature on behalf of that State or any political subdivision or local authority thereof. (b) It is understood that the term “ instrumentality ” includes a person that is wholly owned, directly or indirectly, by a Contracting State or by a political subdivision or local authority of a Contracting State.
Canada–Israel Tax Convention Act, 2016 — C-6.42 (a)
(a) It is understood that the term “ agency ”, in relation to a State or any political subdivision or local authority thereof, includes a body empowered to perform functions or duties of a governmental nature on behalf of that State or any political subdivision or local authority thereof.
Canada–Israel Tax Convention Act, 2016 — C-6.42 (b)
(b) It is understood that the term “ instrumentality ” includes a person that is wholly owned, directly or indirectly, by a Contracting State or by a political subdivision or local authority of a Contracting State.
Canada–Israel Tax Convention Act, 2016 — C-6.42 4
4 With reference to Article 10 (Dividends and Distributions by a Real Estate Investment Fund): (a) It is understood that, in the case of Israel, a “ Real Estate Investment Fund ” means a real estate investment fund which meets the conditions in section 64A3 of the Israeli Income Tax Ordinance . (b) It is understood that the term “ branch tax ” means, in the case of Canada, the tax imposed in accordance with the provisions of Part XIV (Additional Tax on Non-resident Corporations) of the Income Tax Act , as amended from time to time without affecting the general principle hereof.
Canada–Israel Tax Convention Act, 2016 — C-6.42 (a)
(a) It is understood that, in the case of Israel, a “ Real Estate Investment Fund ” means a real estate investment fund which meets the conditions in section 64A3 of the Israeli Income Tax Ordinance .
Canada–Israel Tax Convention Act, 2016 — C-6.42 (b)
(b) It is understood that the term “ branch tax ” means, in the case of Canada, the tax imposed in accordance with the provisions of Part XIV (Additional Tax on Non-resident Corporations) of the Income Tax Act , as amended from time to time without affecting the general principle hereof.
Canada–Israel Tax Convention Act, 2016 — C-6.42 5
5 With reference to paragraph 1 of Article 14 (Income from Employment): It is understood that the term “ similar remuneration ” includes stock-options benefits.
Canada–Israel Tax Convention Act, 2016 — C-6.42
It is understood that the term “ similar remuneration ” includes stock-options benefits.
Canada–Israel Tax Convention Act, 2016 — C-6.42 6
6 With reference to Article 23 (Mutual Agreement Procedure): It is understood that the term “ increase the tax base ” refers to adjustments that result in the inclusion of an item of income or a reduction of an expense or a deduction for tax purposes.
Canada–Israel Tax Convention Act, 2016 — C-6.42
It is understood that the term “ increase the tax base ” refers to adjustments that result in the inclusion of an item of income or a reduction of an expense or a deduction for tax purposes.
Canada–Israel Tax Convention Act, 2016 — C-6.42 7
7 With reference to Article 24 (Exchange of Information): It is understood that information also includes documents.
Canada–Israel Tax Convention Act, 2016 — C-6.42
It is understood that information also includes documents.
Canada–Israel Tax Convention Act, 2016 — C-6.42
SIGNED in duplicate at New York, this 21st day of September 2016, which corresponds to the 18th day of Elul 5776 of the Hebrew Calendar, in the English, French and Hebrew languages, each version being equally authentic.
Canada–Jordan Economic Growth and Prosperity Act — C-6.45
Her Majesty, by and with the advice and consent of the Senate and House of Commons of Canada, enacts as follows:
Canada–Jordan Economic Growth and Prosperity Act — C-6.45 1
Short title 1 This Act may be cited as the Canada–Jordan Economic Growth and Prosperity Act .
Canada–Jordan Economic Growth and Prosperity Act — C-6.45 2
Definitions 2 The definitions in this section apply in this Act. Agreement means the Free Trade Agreement between Canada and the Hashemite Kingdom of Jordan, signed on June 28, 2009. ( Accord ) federal law means the whole or any portion of an Act of Parliament or a regulation, order or other instrument issued, made or established in the exercise of a power conferred by or under an Act of Parliament. ( texte législatif fédéral ) Joint Commission means the Joint Commission established under Article 13-1 of the Agreement. ( Commission mixte ) Minister means the Minister for International Trade. ( ministre ) related agreement means (a) the Agreement on the Environment between Canada and the Hashemite Kingdom of Jordan, signed on June 28, 2009; or (b) the Agreement on Labour Cooperation between Canada and the Hashemite Kingdom of Jordan, signed on June 28, 2009. ( accord connexe )
Canada–Jordan Economic Growth and Prosperity Act — C-6.45
Agreement means the Free Trade Agreement between Canada and the Hashemite Kingdom of Jordan, signed on June 28, 2009. ( Accord )
Canada–Jordan Economic Growth and Prosperity Act — C-6.45
federal law means the whole or any portion of an Act of Parliament or a regulation, order or other instrument issued, made or established in the exercise of a power conferred by or under an Act of Parliament. ( texte législatif fédéral )
Canada–Jordan Economic Growth and Prosperity Act — C-6.45
Joint Commission means the Joint Commission established under Article 13-1 of the Agreement. ( Commission mixte )
Canada–Jordan Economic Growth and Prosperity Act — C-6.45
Minister means the Minister for International Trade. ( ministre )
Canada–Jordan Economic Growth and Prosperity Act — C-6.45 (a)
related agreement means (a) the Agreement on the Environment between Canada and the Hashemite Kingdom of Jordan, signed on June 28, 2009; or (b) the Agreement on Labour Cooperation between Canada and the Hashemite Kingdom of Jordan, signed on June 28, 2009. ( accord connexe )
Canada–Jordan Economic Growth and Prosperity Act — C-6.45 3
Interpretation consistent with agreements 3 For greater certainty, this Act and any federal law that implements a provision of the Agreement or a related agreement or fulfils an obligation of the Government of Canada under the Agreement or a related agreement is to be interpreted in a manner consistent with the Agreement or related agreement, as the case may be.
Canada–Jordan Economic Growth and Prosperity Act — C-6.45 4
Non-application of Act or Agreement to water 4 For greater certainty, nothing in this Act or the Agreement applies to natural surface or ground water in liquid, gaseous or solid state.
Canada–Jordan Economic Growth and Prosperity Act — C-6.45 5
Construction 5 For greater certainty, nothing in this Act, by specific mention or omission, is to be construed to affect in any manner the right of Parliament to enact legislation to implement any provision of the Agreement or a related agreement or fulfil any of the obligations of the Government of Canada under the Agreement or a related agreement.
Canada–Jordan Economic Growth and Prosperity Act — C-6.45 6
Binding on Her Majesty 6 This Act is binding on Her Majesty in right of Canada.
Canada–Jordan Economic Growth and Prosperity Act — C-6.45 7
Purpose 7 The purpose of this Act is to implement the Agreement and the related agreements, the objectives of which, as elaborated more specifically through their provisions, are to (a) establish a free trade area in accordance with the Agreement; (b) promote, through the expansion of reciprocal trade, the harmonious development of the economic relations between Canada and the Hashemite Kingdom of Jordan in order to foster, in both countries, the advancement of economic activity; (c) contribute, by the removal of barriers to trade, to the harmonious development and expansion of world trade; (d) enhance and enforce environmental laws and regulations and strengthen cooperation on environmental matters; (e) protect, enhance and enforce basic workers’ rights, strengthen cooperation on labour matters and build on the respective international commitments of Canada and the Hashemite Kingdom of Jordan on labour matters; and (f) promote sustainable development.
Canada–Jordan Economic Growth and Prosperity Act — C-6.45 8
Causes of action under Part 1 8 (1) No person has any cause of action and no proceedings of any kind shall be taken without the consent of the Attorney General of Canada to enforce or determine any right or obligation that is claimed or arises solely under or by virtue of Part 1 or an order made under that Part. Causes of action under the Agreement or a related agreement (2) Subject to Part Three and Annex 4 of the Agreement on Labour Cooperation between Canada and the Hashemite Kingdom of Jordan, signed on June 28, 2009, no person has any cause of action and no proceedings of any kind shall be taken without the consent of the Attorney General of Canada to enforce or determine any right or obligation that is claimed or arises solely under or by virtue of the Agreement or a related agreement.
Canada–Jordan Economic Growth and Prosperity Act — C-6.45 9
Agreements approved 9 The Agreement and the related agreements are approved.
Canada–Jordan Economic Growth and Prosperity Act — C-6.45 10
Canadian representative on Joint Commission 10 The Minister is the principal representative of Canada on the Joint Commission.
Canada–Jordan Economic Growth and Prosperity Act — C-6.45 11
Payment of expenditures 11 The Government of Canada shall pay its appropriate share of the aggregate of any expenditures incurred by or on behalf of the Joint Commission.
Canada–Jordan Economic Growth and Prosperity Act — C-6.45 12
Powers of Minister 12 (1) The Minister may (a) appoint representatives of Canada to any committee, subcommittee or working group referred to in paragraph 6 of Article 13-1 of the Agreement; (b) appoint a panelist in accordance with Article 14-8 of the Agreement; and (c) propose candidates to serve as the chair of a panel in accordance with that Article 14-8. Powers of Minister of the Environment (2) The Minister of the Environment may (a) appoint representatives of Canada to the committee referred to in Article 15 of the Agreement on the Environment between Canada and the Hashemite Kingdom of Jordan, signed on June 28, 2009; (b) appoint a panelist in accordance with Annex I to that Agreement; and (c) propose candidates to serve as the chairperson of a panel, or select the chairperson, in accordance with that Annex. Powers of the Minister of Labour (3) The Minister of Labour may (a) appoint representatives of Canada to any committee, working group or expert group referred to in Article 7 of the Agreement on Labour Cooperation between Canada and the Hashemite Kingdom of Jordan, signed on June 28, 2009; (b) appoint a panelist in accordance with Annex 3 to that Agreement; and (c) propose candidates to serve as the chairperson of a panel, or select the chairperson, in accordance with that Annex.
Canada–Jordan Economic Growth and Prosperity Act — C-6.45 13
Administrative support 13 The Minister shall designate an agency, division or branch of the Government of Canada to facilitate the operation of Chapter 14 of the Agreement and to provide administrative assistance to panels established under that Chapter.