The Hong Kong treaty qualifies as an agreement with the government of another country
22 April 2015 - 8:55am
Various ITA provisions reference the concept of an agreement with, or with the government of, another country. CRA considers that the Agreement with Hong Kong so qualifies.
Neal Armstrong. Summary of 25 March 2015 T.I. 2014-0560351E5 under s. 248(1) – tax treaty.