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Paid-Up Capital Increase by an Unlimited Liability Company Question The policy underlying Article IV(7)(b) of the Canada-US income tax convention [Footnote 10] is not obvious. ... [Footnote 12] Convention Between Canada and the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital, signed at Luxembourg on September 10, 1999. ... [Footnote 17] IC 76-12R6, Applicable Rate of Part XIII Tax on Amounts Paid or Credited to Persons in Countries with Which Canada Has a Tax Convention, November 2, 2007. ...

A rebate of the GST/HST and the QST paid on convention facilities and related convention supplies may be available to you if you are a  non-resident   exhibitor of foreign or domestic conventions who is not registered for the GST/HST. ... You may claim a rebate for the GST/HST and the QST paid for convention facilities and related convention supplies. Related convention supplies are property and services purchased exclusively for consumption, use, or supply in connection with a convention. ...

Competent Authority Agreements and Notices All jurisdictions Canadian Certificates of Residency not issued to fiscally transparent entities Argentina Canada- Argentina agreement on Argentina’s Certification of Residency Form Barbados Change to withholding tax rate on management fees in the Canada-Barbados Tax Agreement Canada-Barbados Tax Agreement – Agreement between Competent Authorities regarding Article XVI Belgium Canada-Belgium Tax Convention- Agreement between Competent Authorities regarding Article 11 (Interest) Chile Canada-Chile Tax Convention – Most Favoured Nation provision takes effect to reduce the tax rate on interest Changes to the withholding rates on interest and royalties and to the independent personal services Article in the Canada-Chile Tax Convention Change to withholding rate on dividends in the Canada-Chile Tax Convention China Canada-China Income Tax Agreement- Agreement between Competent Authorities regarding paragraphs 3(a)(iv) and 3(b)(iv) of Article 11 Canada-China Income Tax Agreement- Agreement between Competent Authorities regarding paragraph 3 of Article 11 Estonia Canada-Estonia Tax Convention – “Most Favoured Nation” provision takes effects to eliminate source-state taxation rights in respect of certain royalties France Agreement between Competent Authorities regarding Article 12 (Royalties) of the Convention between Canada and France Canada-France agreement concerning a reduction in French taxes on certain payments made to Canadian mutual fund organizations Canada- France agreement concerning the exemption from French tax for certain payments made to pension plans Germany Germany’s Federal Fiscal Court reverses a lower court decision by ruling that Germany may tax Canadian resident recipients of German social security pensions Additional information regarding the change to the taxation of German social security pensions Change to the taxation of social security pensions received from Germany by a resident of Canada- beginning 2005 Hong Kong Canada-Hong Kong Tax Agreement – Arrangement signed between competent authorities on the exchange of Country-by-Country Reports Italy Canada-Italy Tax Convention- Agreement between Competent Authorities regarding Article 11 (Interest) How the new Canada-Italy Tax Convention affects the taxation of pension payments and social security benefits received Korea Canada-Korea Income Tax Convention- Agreement between Competent Authorities regarding Article 11 (Interest) Latvia Canada–Latvia Income Tax Convention: “Most Favoured Nation” provision takes effect to eliminate source-state taxation rights in respect of certain royalties Lithuania Canada–Lithuania Income Tax Convention: “Most Favoured Nation” provision takes effect to eliminate source-state taxation rights in respect of certain royalties Netherlands Canada-Netherlands Income Tax Convention- Agreement between Competent Authorities regarding withholding tax on closed fonds voor gemene rekening (FGR) New Zealand Canada-New Zealand Income Tax Convention – Mode of Application regarding Article 10 (Dividends) Norway Canada-Norway Tax Convention- Agreement between Competent Authorities regarding Article 10 (Dividends) Canada-Norway Tax Convention – Agreement between Competent Authorities regarding Article 11 (Interest) Switzerland Agreement between Canada and Switzerland on refunding Swiss tax on Canadian collective investment vehicle Canada- Switzerland agreement concerning the recognition of social security arrangements for the purposes of Article 27(4) of the Canada-Switzerland Tax Convention Memorandum of Understanding between the Competent Authorities of Canada and Switzerland United States Canada – U.S. ... Tax Convention – Arrangement signed between competent authorities on the exchange of Country-by-Country Reports Canada-U.S. ... Tax Convention Vietnam Canada-Vietnam Income Tax Agreement- Agreement between Competent Authorities regarding Article 11 (Interest) Other Changes to the Taxation of Social Security Benefits for Residents of Certain Countries with Which Canada has an Income Tax Convention Page details Date modified: 2024-02-15 ...

Competent Authority Agreements and Notices Argentina Canada- Argentina agreement on Argentina’s Certification of Residency Form Barbados Change to withholding tax rate on management fees in the Canada-Barbados Tax Agreement Canada-Barbados Tax Agreement – Agreement between Competent Authorities regarding Article XVI Belgium Canada-Belgium Tax Convention- Agreement between Competent Authorities regarding Article 11 (Interest) Chile Changes to the withholding rates on interest and royalties and to the independent personal services Article in the Canada-Chile Tax Convention Change to withholding rate on dividends in the Canada-Chile Tax Convention China Canada-China Income Tax Agreement- Agreement between Competent Authorities regarding paragraphs 3(a)(iv) and 3(b)(iv) of Article 11 Canada-China Income Tax Agreement- Agreement between Competent Authorities regarding paragraph 3 of Article 11 Estonia Canada-Estonia Tax Convention – “Most Favoured Nation” provision takes effects to eliminate source-state taxation rights in respect of certain royalties France Agreement between Competent Authorities regarding Article 12 (Royalties) of the Convention between Canada and France Canada-France agreement concerning a reduction in French taxes on certain payments made to Canadian mutual fund organizations Canada- France agreement concerning the exemption from French tax for certain payments made to pension plans Germany German tax court has ruled in favour of a Canadian recipient of German social security pension Additional information regarding the change to the taxation of German social security pensions Change to the taxation of social security pensions received from Germany by a resident of Canada- beginning 2005 Italy Canada-Italy Tax Convention- Agreement between Competent Authorities regarding Article 11 (Interest) How the new Canada-Italy Tax Convention affects the taxation of pension payments and social security benefits received Korea Canada-Korea Income Tax Convention- Agreement between Competent Authorities regarding Article 11 (Interest) Netherlands Canada-Netherlands Income Tax Convention- Agreement between Competent Authorities regarding withholding tax on closed fonds voor gemene rekening (FGR) New Zealand Canada-New Zealand Income Tax Convention – Mode of Application regarding Article 10 (Dividends) Norway Canada-Norway Tax Convention- Agreement between Competent Authorities regarding Article 10 (Dividends) Canada-Norway Tax Convention – Agreement between Competent Authorities regarding Article 11 (Interest) Switzerland Agreement between Canada and Switzerland on refunding Swiss tax on Canadian collective investment vehicle Canada- Switzerland agreement concerning the recognition of social security arrangements for the purposes of Article 27(4) of the Canada-Switzerland Tax Convention Memorandum of Understanding between the Competent Authorities of Canada and Switzerland United States Canada-U.S. Tax Convention – Arrangement signed between competent authorities on the exchange of Country-by-Country Reports Canada-U.S. ... Tax Convention Vietnam Canada-Vietnam Income Tax Agreement- Agreement between Competent Authorities regarding Article 11 (Interest) Date modified: 2017-06-08 ...

Canada- Argentina Agreement on Argentina's Certification of Residency Form Pursuant to the Canada-Argentina Income Tax Convention (the Convention), the Competent Authorities for Canada and Argentina have entered into an agreement concerning Argentina's Certification of Residency Form (the Form) related to Argentina's General Resolution 3497. The Form is required by the tax administration of Argentina to determine treaty benefits under the Convention. ... In addition, it asks the Competent Authority to confirm, to the best of their knowledge, that a number of other declarations made by the person on the Form are true and correct, including that the person does not have a permanent establishment in Argentina, meets all other requirements of the Convention, and is entitled to the exemptions provided by the Convention. ...

Canada- Argentina Agreement on Argentina's Certification of Residency Form Pursuant to the Canada-Argentina Income Tax Convention (the Convention), the Competent Authorities for Canada and Argentina have entered into an agreement concerning Argentina's Certification of Residency Form (the Form) related to Argentina's General Resolution 3497. The Form is required by the tax administration of Argentina to determine treaty benefits under the Convention. ... In addition, it asks the Competent Authority to confirm, to the best of their knowledge, that a number of other declarations made by the person on the Form are true and correct, including that the person does not have a permanent establishment in Argentina, meets all other requirements of the Convention, and is entitled to the exemptions provided by the Convention. ...

What the "Archived Content" notice means for interpretation bulletins NO: IT-173R2 DATE: January 30, 1989 SUBJECT: INCOME TAX ACT Capital Gains Derived in Canada by Residents of the United States REFERENCE: Article XIII of the 1980 Canada-United States Income Tax Convention (also section 115.1 of the Act and Articles V and VI, paragraph 2(c) of Article XXIV and paragraph 5 of Article XXX of the 1980 Convention and Article VIII of the 1942 Convention). ... The term "fixed base" as used in Article XIII of the 1980 Convention (see 3(b) above) is not defined in the 1980 Convention, but it is intended to relate to the place where independent personal services, rather than industrial or commercial activities, are performed. ... By virtue of paragraph 5 of Article XXX of the 1980 Convention, if Article VIII of the 1942 convention would have afforded greater relief from tax on capital gains than does the 1980 Convention, Article VIII would continue to have full force and effect until the end of the first taxation year of a resident of the United States which commenced on or after January 1, 1985. ...

What the "Archived Content" notice means for interpretation bulletins NO: IT-173R2 DATE: January 30, 1989 SUBJECT: INCOME TAX ACT Capital Gains Derived in Canada by Residents of the United States REFERENCE: Article XIII of the 1980 Canada-United States Income Tax Convention (also section 115.1 of the Act and Articles V and VI, paragraph 2(c) of Article XXIV and paragraph 5 of Article XXX of the 1980 Convention and Article VIII of the 1942 Convention). ... The term "fixed base" as used in Article XIII of the 1980 Convention (see 3(b) above) is not defined in the 1980 Convention, but it is intended to relate to the place where independent personal services, rather than industrial or commercial activities, are performed. ... By virtue of paragraph 5 of Article XXX of the 1980 Convention, if Article VIII of the 1942 convention would have afforded greater relief from tax on capital gains than does the 1980 Convention, Article VIII would continue to have full force and effect until the end of the first taxation year of a resident of the United States which commenced on or after January 1, 1985. ...

What the "Archived Content" notice means for interpretation bulletins NO: IT-173R2 DATE: January 30, 1989 SUBJECT: INCOME TAX ACT Capital Gains Derived in Canada by Residents of the United States REFERENCE: Article XIII of the 1980 Canada-United States Income Tax Convention (also section 115.1 of the Act and Articles V and VI, paragraph 2(c) of Article XXIV and paragraph 5 of Article XXX of the 1980 Convention and Article VIII of the 1942 Convention). ... The term "fixed base" as used in Article XIII of the 1980 Convention (see 3(b) above) is not defined in the 1980 Convention, but it is intended to relate to the place where independent personal services, rather than industrial or commercial activities, are performed. ... By virtue of paragraph 5 of Article XXX of the 1980 Convention, if Article VIII of the 1942 convention would have afforded greater relief from tax on capital gains than does the 1980 Convention, Article VIII would continue to have full force and effect until the end of the first taxation year of a resident of the United States which commenced on or after January 1, 1985. ...

As it may not completely address your particular situation, it would be advisable to refer to the Act, the Regulations, relevant case law or the applicable convention. ... A taxpayer who is faced with a situation of taxation that is not in accordance with the provisions of a convention (for example, double taxation resulting from a transfer pricing audit) may request competent authority assistance pursuant to the Mutual Agreement Procedure (MAP) article of that convention. ... An ACAP does not limit the taxpayer's rights or relieve them from their obligations under the applicable convention or the Act. ...