8 May 1990 Income Tax Severed Letter ACC9115 - Canada-Switzerland Income Tax Convention

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

19(1)

                               HBW 4125-S2
                               David R. Senécal
                               (613) 957-2074

May 8, 1990

Dear 19(1)

Pursuant to paragraph 4 of Article XXIV of the Canada-Switzerland Income Tax Convention signed by our two countries on August 20, 1976, we would like to clarify the application of the said Convention to the taxation of remuneration paid by a political subdivision of a Contracting State to an individual in respect of services rendered to that subdivision. Paragraph 1 of Article XIX of the Convention provides that such remuneration shall be taxable only in the State of source.

We have been informed by officials of the provincial government
of 24(1)   of a proposal of the Swiss federal government to tax   
                    19(1)     in our view, the provisions of
Article XIX  exempt   19(1)  remuneration from taxation by
Switzerland.

We would appreciate your views in this matter.

Yours sincerely, Christine Savage A/Director Provincial and International Relations Division

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