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 — 5
5 There shall be added to Article 29 of the Convention a new paragraph 8, written as follows: “8 Where an enterprise of a Contracting State that is exempt from tax in that State on the profits of its permanent establishments which are not situated in that State derives income from the other Contracting State, and that income is attributable to a permanent establishment which that enterprise has in a third jurisdiction, the tax benefits that would otherwise apply under the other provisions of the Convention will not apply to any item of income on which the combined tax in the first-mentioned State and in the third jurisdiction is less than 60 per cent of the tax that would be imposed in the first-mentioned State if the income were earned or received in that State by the enterprise and were not attributable to the permanent establishment in the third jurisdiction. Any dividends, interest, or royalties to which the provisions of this paragraph apply shall be subject to tax in the other State at a rate not exceeding 15 per cent of the gross amount thereof. Any other income to which the provisions of this paragraph apply shall be subject to tax under the provisions of the domestic law of the other State, notwithstanding any other provision of the Convention. The preceding provisions of this paragraph shall not apply: (a) if the income derived from the other State is in connection with or incidental to the active conduct of a trade or business carried on by the permanent establishment in the third jurisdiction (other than the business of making or managing investments unless these activities are banking or insurance activities carried on by a bank or insurance company); (b) if, when France is the first-mentioned State, France taxes the profits of such permanent establishment according to the provisions of Articles 209B or 209 quinquies of the French “Code général des impôts”, as they may be amended without changing the general principle hereof; or (c) when France is the first-mentioned State, to income taxed by Canada according to section 91 of the Income Tax Act , as it may be amended without changing the general principle hereof.”
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 — “8
“8 Where an enterprise of a Contracting State that is exempt from tax in that State on the profits of its permanent establishments which are not situated in that State derives income from the other Contracting State, and that income is attributable to a permanent establishment which that enterprise has in a third jurisdiction, the tax benefits that would otherwise apply under the other provisions of the Convention will not apply to any item of income on which the combined tax in the first-mentioned State and in the third jurisdiction is less than 60 per cent of the tax that would be imposed in the first-mentioned State if the income were earned or received in that State by the enterprise and were not attributable to the permanent establishment in the third jurisdiction. Any dividends, interest, or royalties to which the provisions of this paragraph apply shall be subject to tax in the other State at a rate not exceeding 15 per cent of the gross amount thereof. Any other income to which the provisions of this paragraph apply shall be subject to tax under the provisions of the domestic law of the other State, notwithstanding any other provision of the Convention. The preceding provisions of this paragraph shall not apply: (a) if the income derived from the other State is in connection with or incidental to the active conduct of a trade or business carried on by the permanent establishment in the third jurisdiction (other than the business of making or managing investments unless these activities are banking or insurance activities carried on by a bank or insurance company); (b) if, when France is the first-mentioned State, France taxes the profits of such permanent establishment according to the provisions of Articles 209B or 209 quinquies of the French “Code général des impôts”, as they may be amended without changing the general principle hereof; or (c) when France is the first-mentioned State, to income taxed by Canada according to section 91 of the Income Tax Act , as it may be amended without changing the general principle hereof.”
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) if the income derived from the other State is in connection with or incidental to the active conduct of a trade or business carried on by the permanent establishment in the third jurisdiction (other than the business of making or managing investments unless these activities are banking or insurance activities carried on by a bank or insurance 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 — (b)
(b) if, when France is the first-mentioned State, France taxes the profits of such permanent establishment according to the provisions of Articles 209B or 209 quinquies of the French “Code général des impôts”, as they may be amended without changing the general principle hereof; or
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) when France is the first-mentioned State, to income taxed by Canada according to section 91 of the Income Tax Act , as it may be amended without changing the general principle hereof.”
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 There shall be added to Article 29 of the Convention a new paragraph 9, written as follows: “9 Subject to reciprocity, the exemptions from tax and other tax benefits provided for by French laws for the benefit of the French State, its local authorities or their agencies or instrumentalities whose activities are not the carrying on of a trade or business, shall apply in the same conditions respectively to: (a) the Canadian State, its provinces, or organisations whose activities are not the carrying on of a trade or business, created within the framework of an agreement concluded or approved by the Contracting States; (b) Canadian local authorities; (c) agencies or instrumentalities of the Canadian State, its provinces or its local authorities, whose activities are identical or substantially similar to those of the French instrumentalities considered. The provisions of this paragraph shall also apply, subject to reciprocity, to French taxes other than those referred to in Article 2, except for taxes owed in respect of services rendered.”
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 — “9
“9 Subject to reciprocity, the exemptions from tax and other tax benefits provided for by French laws for the benefit of the French State, its local authorities or their agencies or instrumentalities whose activities are not the carrying on of a trade or business, shall apply in the same conditions respectively to: (a) the Canadian State, its provinces, or organisations whose activities are not the carrying on of a trade or business, created within the framework of an agreement concluded or approved by the Contracting States; (b) Canadian local authorities; (c) agencies or instrumentalities of the Canadian State, its provinces or its local authorities, whose activities are identical or substantially similar to those of the French instrumentalities considered. The provisions of this paragraph shall also apply, subject to reciprocity, to French taxes other than those referred to in Article 2, except for taxes owed in respect of services rendered.”
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) the Canadian State, its provinces, or organisations whose activities are not the carrying on of a trade or business, created within the framework of an agreement concluded or approved by the Contracting States;
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) agencies or instrumentalities of the Canadian State, its provinces or its local authorities, whose activities are identical or substantially similar to those of the French instrumentalities considered.
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 — 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
The provisions of this paragraph shall also apply, subject to reciprocity, to French taxes other than those referred to in Article 2, except for taxes owed in respect of services rendered.”
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 Paragraph 7 of Article 29 of the Convention shall become paragraph 10.
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 Each Contracting State shall notify to the other the completion of the procedure required for the bringing into force of this Protocol. The Protocol shall enter into force on the first day of the second month following the day on which the later of these notifications is received.
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 the Protocol shall apply: (a) in Canada: (i) in respect of tax withheld at source, for amounts paid or credited to non-residents on or after the day on which the Protocol enters into force; and (ii) in respect of other taxes, for any taxation year beginning on or after the day on which the Protocol enters into force; (b) in France: (i) in respect of the withholding taxes, for any amount paid on or after the day on which the Protocol enters into force; (ii) in respect of taxes on income which are not levied by way of withholding tax, to income earned in any calendar year or relating to any accounting period beginning on or after the day on which the Protocol enters into force; and (iii) in respect of other taxes, to taxation years with respect to taxable events occurring on or after January 1 following the year in which the Protocol enters into force.
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) in Canada: (i) in respect of tax withheld at source, for amounts paid or credited to non-residents on or after the day on which the Protocol enters into force; and (ii) in respect of other taxes, for any taxation year beginning on or after the day on which the Protocol enters into force;
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 — (i)
(i) in respect of tax withheld at source, for amounts paid or credited to non-residents on or after the day on which the Protocol enters into force; 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 — (ii)
(ii) in respect of other taxes, for any taxation year beginning on or after the day on which the Protocol enters into force;
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) in France: (i) in respect of the withholding taxes, for any amount paid on or after the day on which the Protocol enters into force; (ii) in respect of taxes on income which are not levied by way of withholding tax, to income earned in any calendar year or relating to any accounting period beginning on or after the day on which the Protocol enters into force; and (iii) in respect of other taxes, to taxation years with respect to taxable events occurring on or after January 1 following the year in which the Protocol enters into force.
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 — (i)
(i) in respect of the withholding taxes, for any amount paid on or after the day on which the Protocol enters into force;
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 — (ii)
(ii) in respect of taxes on income which are not levied by way of withholding tax, to income earned in any calendar year or relating to any accounting period beginning on or after the day on which the Protocol enters into force; 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 — (iii)
(iii) in respect of other taxes, to taxation years with respect to taxable events occurring on or after January 1 following the year in which the Protocol enters into force.
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 provisions of paragraph 2: (a) the provisions of subparagraph (a) of paragraph 2 of Article 10 of the Convention, as modified by the Protocol, shall apply in respect of Canadian tax withheld at source to amounts paid on or after the day on which the Protocol enters into force, except that the ”5 per cent” percentage shall be replaced by: (i) ”7 per cent” for amounts paid in 1995; and (ii) ”6 per cent” for amounts paid in 1996; (b) the provisions of paragraph 8 of Article 10 of the Convention, as modified by the Protocol, shall apply in respect of other Canadian taxes for taxable periods beginning on or after the day on which the Protocol enters into force, except that the ”5 per cent” percentage is replaced by the following percentages for taxable periods beginning on or after that date and ending in the course of the following years: (i) 1995: “7 per cent”; (ii) 1996: “6 per cent”.
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) the provisions of subparagraph (a) of paragraph 2 of Article 10 of the Convention, as modified by the Protocol, shall apply in respect of Canadian tax withheld at source to amounts paid on or after the day on which the Protocol enters into force, except that the ”5 per cent” percentage shall be replaced by: (i) ”7 per cent” for amounts paid in 1995; and (ii) ”6 per cent” for amounts paid in 1996;
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 — (i)
(i) ”7 per cent” for amounts paid in 1995; 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 — (ii)
(ii) ”6 per cent” for amounts paid in 1996;
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) the provisions of paragraph 8 of Article 10 of the Convention, as modified by the Protocol, shall apply in respect of other Canadian taxes for taxable periods beginning on or after the day on which the Protocol enters into force, except that the ”5 per cent” percentage is replaced by the following percentages for taxable periods beginning on or after that date and ending in the course of the following years: (i) 1995: “7 per cent”; (ii) 1996: “6 per cent”.
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 Notwithstanding the provisions of paragraph 2, the provisions of paragraph 9 of Article 29 of the Convention, as modified by the Protocol, shall apply for taxation years not prescribed on the date of entry into force of the Protocol.
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 the Convention between Canada and France for the avoidance of double taxation and the prevention of fiscal evasion in relation to succession duties signed at Paris on March 16, 1951, shall cease to have effect with respect to estates of persons deceased on or after the first day of January of the year next following that during which the Protocol enters into force. That Convention shall terminate on the last date on which it has effect in accordance with the provisions of this paragraph.
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 The Agreement of October 19, 1932, providing for the exemption from taxation of profits derived from the operation of ships is terminated.
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 This Protocol shall remain in force as long as the Convention remains in force.
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 competent authorities of the Contracting States shall be empowered, after the entry into force of the Protocol, to publish the text of the Convention as amended by the Protocol of January 16, 1987 and by this Protocol.
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 — 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
IN WITNESS WHEREOF the undersigned, duly authorized to that effect, have signed this Protocol.