GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 (a)
(a) in the territory in which the income tax law administered by the Canada Revenue Agency is applied: (i) in respect of tax withheld at the source on amounts paid or credited to non-residents on or after the first day of January in the calendar year following that which includes the date of the later notification; and (ii) in respect of other tax, for taxation years beginning on or after the first day of January in the calendar year following that which includes the date of the later notification; and
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 (i)
(i) in respect of tax withheld at the source on amounts paid or credited to non-residents on or after the first day of January in the calendar year following that which includes the date of the later notification; and
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 (ii)
(ii) in respect of other tax, for taxation years beginning on or after the first day of January in the calendar year following that which includes the date of the later notification; and
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 (b)
(b) in the territory in which the taxation law administered by the Taxation Administration, Ministry of Finance, Taiwan is applied: (i) in respect of tax withheld at the source on amounts paid or payable to non-residents on or after the first day of January in the calendar year following that which includes the date of the later notification; and (ii) in respect of other tax, for taxation years beginning on or after the first day of January in the calendar year following that which includes the date of the later notification;
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 (i)
(i) in respect of tax withheld at the source on amounts paid or payable to non-residents on or after the first day of January in the calendar year following that which includes the date of the later notification; and
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 (ii)
(ii) in respect of other tax, for taxation years beginning on or after the first day of January in the calendar year following that which includes the date of the later notification;
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 (c)
(c) in respect of Section 25 for information that relates to taxation years beginning on or after the first day of January in the calendar year following that which includes the date of the later notification.
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 (a)
This Arrangement will continue to have effect indefinitely but either the Canadian Trade Office in Taipei or the Taipei Economic and Cultural Office in Canada may, on or before 30 June of any calendar year following the year which includes the date of the later notification referred to in Section 27, give to the other Office a notice of termination in writing. In such event, the Arrangement will cease to have effect: (a) in the territory in which the income tax law administered by the Canada Revenue Agency is applied: (i) in respect of tax withheld at the source on amounts paid or credited to non-residents, after the end of that calendar year; and (ii) in respect of other tax, for taxation years beginning after the end of that calendar year; and (b) in the territory in which the taxation law administered by the Taxation Administration, Ministry of Finance, Taiwan is applied: (i) in respect of tax withheld at the source on amounts paid or payable to non-residents, after the end of that calendar year; and (ii) in respect of other tax, for taxation years beginning after the end of that calendar year.
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 (a)
(a) in the territory in which the income tax law administered by the Canada Revenue Agency is applied: (i) in respect of tax withheld at the source on amounts paid or credited to non-residents, after the end of that calendar year; and (ii) in respect of other tax, for taxation years beginning after the end of that calendar year; and
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 (i)
(i) in respect of tax withheld at the source on amounts paid or credited to non-residents, after the end of that calendar year; and
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 (ii)
(ii) in respect of other tax, for taxation years beginning after the end of that calendar year; and
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 (b)
(b) in the territory in which the taxation law administered by the Taxation Administration, Ministry of Finance, Taiwan is applied: (i) in respect of tax withheld at the source on amounts paid or payable to non-residents, after the end of that calendar year; and (ii) in respect of other tax, for taxation years beginning after the end of that calendar year.
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 (i)
(i) in respect of tax withheld at the source on amounts paid or payable to non-residents, after the end of that calendar year; and
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 (ii)
(ii) in respect of other tax, for taxation years beginning after the end of that calendar year.
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5
SIGNED in duplicate at Ottawa, on this 13th day of January 2016, and at Taipei, on this 15th day of January 2016, in the English, French and Chinese languages, each version being equally valid.
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5
FOR THE CANADIAN TRADE OFFICE IN TAIPEI Mario Ste-Marie Executive Director
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5
FOR THE TAIPEI ECONOMIC AND CULTURAL OFFICE IN CANADA Rong-chuan Wu Representative
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5
At the time of signing of this Arrangement Between the Canadian Trade Office in Taipei and the Taipei Economic and Cultural Office in Canada for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income , the undersigned have agreed upon the following provisions which will be an integral part of the Arrangement. It is understood that:
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 1
1 With reference to paragraph 1 of Section 4, the term “ instrumentality ” means any entity created or organized by the authority administering either territory or a subdivision thereof in order to carry out functions of a governmental nature.
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 2
2 With reference to paragraph 4 of Section 13, for greater certainty, the term “ the value of which is derived ” means whether such value is derived directly or indirectly.
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 3
3 With reference to paragraph 4 of Section 13, “ principally ” means more than 50 per cent.
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 4
4 With reference to paragraph 6 of Section 13, it is understood that the determination of the gain that accrued in a territory while an individual was a resident of that territory in respect of a property will be made by reference to the lesser of the fair market value of the property at the time that the individual ceased to be a resident of that territory or the proceeds of disposition realized at the time of the actual alienation of the property.
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 5
5 With reference to paragraph 1 of Section 14, where income derived by a resident of a territory in respect of professional services or other activities of an independent character may be taxed in the other territory, there will be allowed as deductions expenses which are incurred for the purposes of performing such services in determining taxable income.
Canada and Taiwan Territories Tax Arrangement Act, 2016 — C-0.5 6
6 With reference to Section 25, it is understood that its provisions do not require the territories to exchange information on an automatic or a spontaneous basis.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 19
Citation of Part IV 19 This Part may be cited as the Canada-Argentina Income Tax Convention Act, 1994 .
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 20
Definition of Convention 20 In this Part, Convention means the Convention between the Government of Canada and the Government of the Argentine Republic set out in Schedule V, as amended by the Protocol set out in Schedule VI.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 21
Convention approved 21 The Convention is approved and has the force of law in Canada during the period that the Convention, by its terms, is in force.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 22
Inconsistent laws 22 (1) Subject to subsection (2), in the event of any inconsistency between the provisions of this Part or the Convention and the provisions of any other law, the provisions of this Part and the Convention prevail to the extent of the inconsistency. Idem (2) In the event of any inconsistency between the provisions of the Income Tax Conventions Interpretation Act and the provisions of the Convention, the provisions of that Act prevail to the extent of the inconsistency.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 23
Regulations 23 The Minister of National Revenue may make any regulations that are necessary for carrying out the Convention or for giving effect to any of its provisions.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 Publication of notice
Publication of notice * 24 The Minister of Finance shall cause a notice of the day on which the Convention enters into force and of the day on which it ceases to have effect to be published in the Canada Gazette within sixty days after its ratification or termination. * [Note: Convention in force December 30, 1994, see Canada Gazette Part I, Volume 129, page 257.]
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6
The Government of Canada and the Government of the Argentine Republic, desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, have agreed as follows:
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6
This Convention shall apply to persons who are residents of one or both of the Contracting States.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 This Convention shall apply to taxes on income and on capital imposed on behalf of each Contracting State, irrespective of the manner in which they are levied.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, as well as taxes on capital appreciation.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 3
3 The existing taxes to which the Convention shall apply are, in particular: (a) in the case of Canada: the taxes imposed by the Government of Canada under the Income Tax Act , (hereinafter referred to as “Canadian tax”); (b) in the case of Argentina: (i) the income tax ( impuesto a las ganancias ); (ii) the assets tax ( impuesto sobre los activos ); and (iii) the personal assets tax ( impuesto personal sobre los bienes no incorporados al proceso economico ); (hereinafter referred to as “Argentine tax”).
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
(a) in the case of Canada: the taxes imposed by the Government of Canada under the Income Tax Act , (hereinafter referred to as “Canadian tax”);
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6
the taxes imposed by the Government of Canada under the Income Tax Act , (hereinafter referred to as “Canadian tax”);
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (b)
(b) in the case of Argentina: (i) the income tax ( impuesto a las ganancias ); (ii) the assets tax ( impuesto sobre los activos ); and (iii) the personal assets tax ( impuesto personal sobre los bienes no incorporados al proceso economico ); (hereinafter referred to as “Argentine tax”).
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (i)
(i) the income tax ( impuesto a las ganancias );
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (ii)
(ii) the assets tax ( impuesto sobre los activos ); and
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (iii)
(iii) the personal assets tax ( impuesto personal sobre los bienes no incorporados al proceso economico ); (hereinafter referred to as “Argentine tax”).
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6
(hereinafter referred to as “Argentine tax”).
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 4
4 The Convention shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of significant changes which have been made in their respective taxation laws.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 For the purposes of this Convention, unless the context otherwise requires: (a) the terms a Contracting State and the other Contracting State mean, as the context requires, Canada or Argentina; (b) the term person includes an individual, a company and any other body of persons; in the case of Canada it also includes an estate, a trust and a partnership; (c) the term company means any body corporate or any entity which is treated as a body corporate for tax purposes; in French, the term société also means a corporation within the meaning of Canadian law; (d) the terms enterprise of a Contracting State and enterprise of the other Contracting State mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State; (e) the term international traffic means any voyage of a ship or aircraft operated by an enterprise of a Contracting State to transport passengers or property except where the principal purpose of the voyage is to transport passengers or property between places within the other Contracting State; (f) the term tax means Canadian tax or Argentine tax, as the context requires; (g) the term national means: (i) any individual possessing the nationality of a Contracting State; (ii) any legal person, partnership and association deriving its status as such from the laws in force in a Contracting State; (h) the term competent authority means: (i) in the case of Canada, the Minister of National Revenue or his authorized representative, (ii) in the case of Argentina, the Ministry of Economy, Secretary of Public Revenue (el Ministerio de Economía, Secretaría de Ingresos Públicos).
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
(a) the terms a Contracting State and the other Contracting State mean, as the context requires, Canada or Argentina;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (b)
(b) the term person includes an individual, a company and any other body of persons; in the case of Canada it also includes an estate, a trust and a partnership;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (c)
(c) the term company means any body corporate or any entity which is treated as a body corporate for tax purposes; in French, the term société also means a corporation within the meaning of Canadian law;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (d)
(d) the terms enterprise of a Contracting State and enterprise of the other Contracting State mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (e)
(e) the term international traffic means any voyage of a ship or aircraft operated by an enterprise of a Contracting State to transport passengers or property except where the principal purpose of the voyage is to transport passengers or property between places within the other Contracting State;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (f)
(f) the term tax means Canadian tax or Argentine tax, as the context requires;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (g)
(g) the term national means: (i) any individual possessing the nationality of a Contracting State; (ii) any legal person, partnership and association deriving its status as such from the laws in force in a Contracting State;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (i)
(i) any individual possessing the nationality of a Contracting State;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (ii)
(ii) any legal person, partnership and association deriving its status as such from the laws in force in a Contracting State;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (h)
(h) the term competent authority means: (i) in the case of Canada, the Minister of National Revenue or his authorized representative, (ii) in the case of Argentina, the Ministry of Economy, Secretary of Public Revenue (el Ministerio de Economía, Secretaría de Ingresos Públicos).
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (i)
(i) in the case of Canada, the Minister of National Revenue or his authorized representative,
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (ii)
(ii) in the case of Argentina, the Ministry of Economy, Secretary of Public Revenue (el Ministerio de Economía, Secretaría de Ingresos Públicos).
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 As regards the application of the Convention by a Contracting State at any time, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has at that time under the law of that State concerning the taxes to which the Convention applies.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 For the purposes of this Convention, the term resident of a Contracting State means: (a) any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management, place or incorporation or any other criterion of a similar nature; (b) the government of that State or a political subdivision or local authority thereof or any agency or instrumentality of any such government, subdivision or authority.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
(a) any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management, place or incorporation or any other criterion of a similar nature;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (b)
(b) the government of that State or a political subdivision or local authority thereof or any agency or instrumentality of any such government, subdivision or authority.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: (a) he shall be deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident of the State of which he is a national; (d) if he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
(a) he shall be deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (centre of vital interests);
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (b)
(b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (c)
(c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident of the State of which he is a national;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (d)
(d) if he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 3
3 Where by reason of the provisions of paragraph 1 a company is a resident of both Contracting States, then its status shall be determined as follows: (a) it shall be deemed to be a resident of the State of which it is a national; (b) if it is a national of neither of the States, it shall be deemed to be a resident of the State in which its place of effective management is situated.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
(a) it shall be deemed to be a resident of the State of which it is a national;
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (b)
(b) if it is a national of neither of the States, it shall be deemed to be a resident of the State in which its place of effective management is situated.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 4
4 Where by reason of the provisions of paragraph 1 a person other than an individual or a company is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavour to settle the question and to determine the mode of application of the Convention to such person.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 1
1 For the purposes of this Convention, the term permanent establishment means a fixed place of business through which the business of an enterprise of a Contracting State is wholly or partly carried on.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 2
2 The term permanent establishment includes especially: (a) a place of management; (b) a branch; (c) an office; (d) a factory; (e) a workshop; and (f) a mine, an oil or gas well, a quarry or any other place relating to the exploration for or the exploitation of natural resources.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (f)
(f) a mine, an oil or gas well, a quarry or any other place relating to the exploration for or the exploitation of natural resources.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 3
3 The term permanent establishment likewise encompasses: (a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than six months; (b) the furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only where such activities continue within the country for a period or periods aggregating more than six months within any twelve month period.
Canada-Argentina Income Tax Convention Act, 1994 — C-0.6 (a)
(a) a building site, a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than six months;