GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — (a)
(a) Gains from the alienation of immovable property may be taxed in the Contracting State in which such property is situated.
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — (b)
(b) Gains from the alienation of shares or other rights in a company the assets of which consist principally of immovable property situated in a Contracting State may be taxed in that State.
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — (c)
(c) Gains from the alienation of an interest in a partnership or a trust the assets of which consist principally of immovable property situated in a Contracting State may be taxed in that State.
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — (d)
(d) For the purposes of subparagraphs (b) and (c), and for the purposes of paragraph 2 of Article 22, the term “immovable property situated in a Contracting State” includes immovable property situated in that State which is referred to in Article 6, and the shares or other rights the value of which is derived, directly or indirectly, principally from immovable property situated in that State, and an interest in a partnership or trust, the value of which is derived, directly or indirectly, principally from immovable property situated in that State; but it does not include property, other than rental property, through which the business of the company, partnership or trust is carried on.”
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — 2
2 Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base may be taxed in that other State.
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — 3
3 Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated by that enterprise in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that State.
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — 4
4 Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — 5
5 The provisions of paragraph 4 shall not prevent a Contracting State from taxing, according to its law, gains derived by an individual who is a resident of the other Contracting State from the alienation of any property, if the alienator: (a) is a national of the first-mentioned State or has been a resident of that State for ten years or more prior to the date of the alienation of the property, and (b) has been a resident of that first-mentioned State at any time within the five year period immediately preceding the date of the alienation.”
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — (a)
(a) is a national of the first-mentioned State or has been a resident of that State for ten years or more prior to the date of the alienation of the property, and
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — (b)
(b) has been a resident of that first-mentioned State at any time within the five year period immediately preceding the date of the alienation.”
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — “3
Paragraph 3 of Article 15 of the Convention shall be deleted and replaced by the following: “3 Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.”
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — “3
“3 Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.”
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — “ARTICLE 17
Article 17 of the Convention shall be deleted and replaced by the following: “ARTICLE 17 Artistes and Sportsmen 1 Notwithstanding the provisions of Articles 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. 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. 3 The provisions of paragraphs 1 and 2 shall not apply to income in respect of activities exercised by a resident of a Contracting State as an entertainer or a sportsman in the other Contracting State if the visit to that other State is principally supported, directly or indirectly, by public funds of the first-mentioned State, its provinces in the case of Canada, its local authorities, or their agencies or instrumentalities thereof. In such case, the income shall be taxable only in the first-mentioned State.”
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — 1
1 Notwithstanding the provisions of Articles 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.
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — 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.
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — 3
3 The provisions of paragraphs 1 and 2 shall not apply to income in respect of activities exercised by a resident of a Contracting State as an entertainer or a sportsman in the other Contracting State if the visit to that other State is principally supported, directly or indirectly, by public funds of the first-mentioned State, its provinces in the case of Canada, its local authorities, or their agencies or instrumentalities thereof. In such case, the income shall be taxable only in the first-mentioned State.”
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — “2
Paragraph 2 of Article 18 of the Convention shall be deleted and replaced by the following: “2 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, notwithstanding the provisions of Article 23, 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.”
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — “2
“2 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, notwithstanding the provisions of Article 23, 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.”
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — “ARTICLE 19
Article 19 of the Convention shall be deleted and replaced by the following: “ARTICLE 19 Government Service 1 Salaries, wages and other similar remuneration, other than a pension, paid by a Contracting State or a province in the case of Canada or a local authority or an instrumentality thereof to an individual who is a national of that State in respect of services rendered to that State, province, authority or agency or instrumentality, shall be taxable only in that State. 2 The provisions of paragraph 1 shall not apply to salaries, wages and other similar remuneration paid in respect of services rendered in connection with a trade or business carried on by a Contracting State, a province in the case of Canada, a local authority, or by one of their agencies or instrumentalities.”
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — 1
1 Salaries, wages and other similar remuneration, other than a pension, paid by a Contracting State or a province in the case of Canada or a local authority or an instrumentality thereof to an individual who is a national of that State in respect of services rendered to that State, province, authority or agency or instrumentality, shall be taxable only in that State.
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — 2
2 The provisions of paragraph 1 shall not apply to salaries, wages and other similar remuneration paid in respect of services rendered in connection with a trade or business carried on by a Contracting State, a province in the case of Canada, a local authority, or by one of their agencies or instrumentalities.”
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — “ARTICLE 22
Article 22 of the Convention shall be deleted and replaced by the following: “ARTICLE 22 Capital 1 Capital represented by immovable property owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other State. 2 Capital represented by shares or other rights in a company the assets of which consist principally of immovable property situated in a Contracting State and referred to in subparagraph (d) of paragraph 1 of Article 13, may be taxed in that State. 3 Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting state has in the other Contracting State or by movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, may be taxed in that other State. 4 Capital represented by shares or other rights (other than shares or other rights referred to in paragraph 2) forming part of a substantial interest in a company which is a resident of a Contracting State may be taxed in that State. A substantial interest is considered to exist when an individual holds, alone or with related persons, directly or indirectly, shares or other rights the total of which gives right to at least 25 per cent of the profits of the company. 5 Capital of an enterprise of a Contracting State represented by ships and aircraft operated by that enterprise in international traffic or by movable property pertaining to their operation, or by containers referred to in paragraph 4 of Article 8, shall be taxable only in that State. 6 All other elements of capital of a resident of a Contracting State shall be taxable only in that State. 7 Notwithstanding the preceding provisions of this Article, for the purposes of taxation with respect to the solidarity tax on net wealth referred to in subparagraph (b) of paragraph 3 of Article 2 of an individual who is a resident of France and who is a national of Canada but not a national of France, the assets situated outside of France that such person owns on the first of January of each of the five years following the calendar year in which he becomes a resident of France shall be excluded from the base of assessment of the taxes relating to each of those five years. If such an individual loses the status of resident of France for a period of at least three years and then again becomes a resident of France, the assets situated outside of France that such a person owns on the first of January of each of the five years following the calendar year in which again he becomes a resident of France shall be excluded from the base of assessment of the taxes relating to each of those five years.”
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — 1
1 Capital represented by immovable property owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other State.
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — 2
2 Capital represented by shares or other rights in a company the assets of which consist principally of immovable property situated in a Contracting State and referred to in subparagraph (d) of paragraph 1 of Article 13, may be taxed in that State.
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — 3
3 Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting state has in the other Contracting State or by movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, may be taxed in that other State.
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — 4
4 Capital represented by shares or other rights (other than shares or other rights referred to in paragraph 2) forming part of a substantial interest in a company which is a resident of a Contracting State may be taxed in that State. A substantial interest is considered to exist when an individual holds, alone or with related persons, directly or indirectly, shares or other rights the total of which gives right to at least 25 per cent of the profits of the company.
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — 5
5 Capital of an enterprise of a Contracting State represented by ships and aircraft operated by that enterprise in international traffic or by movable property pertaining to their operation, or by containers referred to in paragraph 4 of Article 8, shall be taxable only in that State.
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — 6
6 All other elements of capital of a resident of a Contracting State shall be taxable only in that State.
Proclamation giving notice that the annexed November 30, 1995 supplementary agreement, entitled Protocol to the Tax Convention Between the Government of Canada and the Government of the French Republic signed on May 2, 1975 and amended by the Protocol of January 16, 1987, came into force on September 1, 1998 — 7
7 Notwithstanding the preceding provisions of this Article, for the purposes of taxation with respect to the solidarity tax on net wealth referred to in subparagraph (b) of paragraph 3 of Article 2 of an individual who is a resident of France and who is a national of Canada but not a national of France, the assets situated outside of France that such person owns on the first of January of each of the five years following the calendar year in which he becomes a resident of France shall be excluded from the base of assessment of the taxes relating to each of those five years. If such an individual loses the status of resident of France for a period of at least three years and then again becomes a resident of France, the assets situated outside of France that such a person owns on the first of January of each of the five years following the calendar year in which again he becomes a resident of France shall be excluded from the base of assessment of the taxes relating to each of those five years.”