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7 February 1991 Income Tax Severed Letter- Canada-Malta Income Tax Agreement Unedited CRA Tags Canada-Malta Income Tax Convention, Art. 28(4) Dear Sir: Re: Canada-Malta Income Tax Agreement, 1986 (the “Agreement”) This is in reply to your letter to the Canadian Embassy in Rome dated November 23, 1990, whereby you inquired concerning the application of paragraph (4) of Article 28 of the above-noted Agreement in respect of an offshore company registered under the Malta International Business Activities Act, 1988 that has waived in part the benefits of that Act by electing to pay tax at a rate higher than applicable to it under that Act but below the standard rate for companies owned by residents of Malta. ...

The Canada-United States Income Tax Convention (1980) does not provide for a reduction of Part XIII tax on such rental income. ...

15 January 1993 Income Tax Severed Letter 9238305- Withholding Tax—Barbados International Business Company Unedited CRA Tags 212(1)(b), Canada–Barbados Income Tax Convention Article XXX 923830 XXXXXXXXXX K. ...

21 June 1984 Income Tax Severed Letter A-9866 Unedited CRA Tags 212(1)(f), Canada-Germany 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 Department. ...

Accordingly, you are of the view that interest payments from Canco to the Swedish parent would not be subject to Part XIII withholding taxes because of paragraph 6 of Article 11 of the Canada-Sweden Income Tax Convention. ...

We note that there is nothing in the Canada-Netherlands Tax Convention which overrides the Act in this regard. ...

Income Tax Convention Art. XVII This is further to our memorandum of November 27, 1989 concerning the above subject matter. ...

Tax Convention Canada-U.S. Tax Treaty:Art. XII Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

Tax Conventions ...

Tax Convention provides that income received from an estate or trust resident in Canada by a resident of the United Kingdom who is a beneficial owner shall not exceed 15% of the gross amount of the payment. ...