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 If any question, difficulty or doubt arising as to the interpretation or application of the Convention cannot be resolved or dealt with by the competent authorities as a result of the application of the provisions of paragraphs 1, 2 or 3, these questions, difficulties or doubts may, if the competent authorities agree, be submitted to an arbitration commission. The decisions of the commission shall have the force of law. The composition of the commission and the arbitration procedures shall be determined, after consultation between the competent authorities, through an exchange of diplomatic notes between the Contracting States. The provisions of this paragraph shall take effect from the date agreed to in the exchange of diplomatic notes.”
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 26
Article 26 of the Convention shall be deleted and replaced by the following: “ARTICLE 26 Exchange of Information 1 The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Convention or of the domestic laws of the Contracting States concerning taxes covered by the Convention insofar as the taxation thereunder is not contrary to the Convention. The exchange of information is not restricted by Article 1. Any information received 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) involved in the assessment or collection of, the enforcement in respect of, or the determination of appeals in relation to, the taxes covered by the Convention. 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. 2 In no case shall the provisions of paragraph 1 be construed so as to impose on a Contracting State the obligation: (a) to carry out administrative measures at variance with the laws and 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).”
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 The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Convention or of the domestic laws of the Contracting States concerning taxes covered by the Convention insofar as the taxation thereunder is not contrary to the Convention. The exchange of information is not restricted by Article 1. Any information received 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) involved in the assessment or collection of, the enforcement in respect of, or the determination of appeals in relation to, the taxes covered by the Convention. 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.
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 In no case shall the provisions of paragraph 1 be construed so as to impose on a Contracting State the obligation: (a) to carry out administrative measures at variance with the laws and 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).”
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) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting 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 — (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;
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) 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).”
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 Paragraph 1 of Article 29 of the Convention shall be deleted and replaced by the following: “1 The provisions of this Convention shall not prevent: (a) Canada from imposing a tax on amounts included in the income of a resident of Canada with respect to a partnership, trust, or controlled foreign affiliate, in which he has an interest; (b) France from applying the provisions of Articles 209B and 212 of the “Code général des impôts” or other identical or substantially similar provisions which would amend or replace them.”
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 The provisions of this Convention shall not prevent: (a) Canada from imposing a tax on amounts included in the income of a resident of Canada with respect to a partnership, trust, or controlled foreign affiliate, in which he has an interest; (b) France from applying the provisions of Articles 209B and 212 of the “Code général des impôts” or other identical or substantially similar provisions which would amend or replace them.”
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) Canada from imposing a tax on amounts included in the income of a resident of Canada with respect to a partnership, trust, or controlled foreign affiliate, in which he has an interest;
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) France from applying the provisions of Articles 209B and 212 of the “Code général des impôts” or other identical or substantially similar provisions which would amend or replace them.”
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 Paragraph 3 of Article 29 of the Convention shall be deleted and replaced by the following: “3 The competent authorities of the Contracting States may settle the mode of application of the Convention. In particular, they may prescribe the formalities that must be followed by a resident of a Contracting State to obtain, in the other Contracting State, the exemptions or reductions of tax or other tax benefits provided for by the Convention. Such formalities may include the filing of a form certifying residency, indicating in particular the nature and the amount or value of the income or of the capital in question, certified by the tax authorities 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 — “3
“3 The competent authorities of the Contracting States may settle the mode of application of the Convention. In particular, they may prescribe the formalities that must be followed by a resident of a Contracting State to obtain, in the other Contracting State, the exemptions or reductions of tax or other tax benefits provided for by the Convention. Such formalities may include the filing of a form certifying residency, indicating in particular the nature and the amount or value of the income or of the capital in question, certified by the tax authorities 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 — 3
3 Paragraph 5 of Article 29 of the Convention shall be deleted and replaced by the following: “5 Contributions in a year in respect of services rendered in that year paid by, or on behalf of, an individual who is a resident of one of the Contracting States or who is temporarily present in that State, to a pension plan that is recognized for tax purposes in the other Contracting State shall, during a period not exceeding in the aggregate sixty months, be treated in the same way for tax purposes in the first-mentioned State as a contribution paid to a pension plan that is recognized for tax purposes in the first-mentioned State, provided that: (a) such individual was regularly contributing to the pension plan (or to another pension plan for which that plan has been substituted) over a period ending immediately before he became a resident of or temporarily present in the first-mentioned State; and (b) the competent authority of the first-mentioned State agrees that the pension plan corresponds generally to a pension plan recognized for tax purposes by that State. For the purposes of this paragraph, the term pension plan includes especially a pension plan created under a public social security system.”
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 Contributions in a year in respect of services rendered in that year paid by, or on behalf of, an individual who is a resident of one of the Contracting States or who is temporarily present in that State, to a pension plan that is recognized for tax purposes in the other Contracting State shall, during a period not exceeding in the aggregate sixty months, be treated in the same way for tax purposes in the first-mentioned State as a contribution paid to a pension plan that is recognized for tax purposes in the first-mentioned State, provided that: (a) such individual was regularly contributing to the pension plan (or to another pension plan for which that plan has been substituted) over a period ending immediately before he became a resident of or temporarily present in the first-mentioned State; and (b) the competent authority of the first-mentioned State agrees that the pension plan corresponds generally to a pension plan recognized for tax purposes by that State. For the purposes of this paragraph, the term pension plan includes especially a pension plan created under a public social security system.”
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) such individual was regularly contributing to the pension plan (or to another pension plan for which that plan has been substituted) over a period ending immediately before he became a resident of or temporarily present in the first-mentioned State; 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) the competent authority of the first-mentioned State agrees that the pension plan corresponds generally to a pension plan recognized for tax purposes by 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 — 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
For the purposes of this paragraph, the term pension plan includes especially a pension plan created under a public social security system.”
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 There shall be added to Article 29 of the Convention a new paragraph 7, written as follows: “7 (a) A mutual fund in securities constituted and established in a Contracting State, not subject to tax in that State, and which receives dividends paid by a company which is a resident of the other Contracting State or interest arising in that other State, may claim as a whole the benefit of the reductions or exemptions of taxes provided for under the Convention for the fraction of the income which corresponds to the rights held in that organisation by residents of the first-mentioned State and which is taxable in the hands of those residents. (b) Notwithstanding the provisions of Article 10, dividends paid by a company which is a resident of a Contracting State to an organisation that was constituted and is established in the other Contracting State and is operated exclusively to administer or provide benefits under one or more pension or retirement plans, shall be exempt from tax in the first-mentioned State provided that: (i) the organisation is the beneficial owner of the dividends and is generally exempt from tax in the other State; and (ii) the organisation does not own directly or indirectly more than 5 per cent of the capital nor more than 5 per cent of the voting stock of the company paying the dividends; and (iii) the principal class of shares of the company paying the dividends is regularly traded on a stock exchange situated in the first-mentioned State. (c) Notwithstanding the provisions of Article 11, interest arising in a Contracting State and paid to an organisation that was constituted and is established in the other Contracting State and is operated exclusively to administer or provide benefits under one or more pension or retirement plans, shall be exempt from tax in the first-mentioned State provided that: (i) the organisation is the beneficial owner of the interest and is generally exempt from tax in the other State; and (ii) the interest is not derived from the carrying on a trade or a business by the organisation or from an associated person within the meaning of subparagraphs (a) or (b) of Article 9.”
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) A mutual fund in securities constituted and established in a Contracting State, not subject to tax in that State, and which receives dividends paid by a company which is a resident of the other Contracting State or interest arising in that other State, may claim as a whole the benefit of the reductions or exemptions of taxes provided for under the Convention for the fraction of the income which corresponds to the rights held in that organisation by residents of the first-mentioned State and which is taxable in the hands of those residents.
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) Notwithstanding the provisions of Article 10, dividends paid by a company which is a resident of a Contracting State to an organisation that was constituted and is established in the other Contracting State and is operated exclusively to administer or provide benefits under one or more pension or retirement plans, shall be exempt from tax in the first-mentioned State provided that: (i) the organisation is the beneficial owner of the dividends and is generally exempt from tax in the other State; and (ii) the organisation does not own directly or indirectly more than 5 per cent of the capital nor more than 5 per cent of the voting stock of the company paying the dividends; and (iii) the principal class of shares of the company paying the dividends is regularly traded on a stock exchange situated 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 — (i)
(i) the organisation is the beneficial owner of the dividends and is generally exempt from tax in the other State; 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) the organisation does not own directly or indirectly more than 5 per cent of the capital nor more than 5 per cent of the voting stock of the company paying the dividends; 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) the principal class of shares of the company paying the dividends is regularly traded on a stock exchange situated 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 — (c)
(c) Notwithstanding the provisions of Article 11, interest arising in a Contracting State and paid to an organisation that was constituted and is established in the other Contracting State and is operated exclusively to administer or provide benefits under one or more pension or retirement plans, shall be exempt from tax in the first-mentioned State provided that: (i) the organisation is the beneficial owner of the interest and is generally exempt from tax in the other State; and (ii) the interest is not derived from the carrying on a trade or a business by the organisation or from an associated person within the meaning of subparagraphs (a) or (b) of Article 9.”
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) the organisation is the beneficial owner of the interest and is generally exempt from tax in the other State; 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) the interest is not derived from the carrying on a trade or a business by the organisation or from an associated person within the meaning of subparagraphs (a) or (b) of Article 9.”