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Convention-- [NAME OF THE RELEVANT CONVENTION]. Critical assumption-- Any assumed objective criterion that would significantly affect the substantive terms of the APA if the underlying conditions changed, whether or not the change is within the taxpayer's control. ... Consequently, the confidentiality provisions of the Act and the Convention limit the rights and powers of the CCRA to use and disclose information submitted in connection with an APA. ... CHANGE IN LAW OR TO THE CONVENTION If there is a change in law or to the Convention that modifies the Canadian federal income tax treatment of any matter covered by this APA, the new or amended law or the Convention will supersede this APA to the extent that it is inconsistent. 19. ...

Convention-- [NAME OF THE RELEVANT CONVENTION]. Critical assumption-- Any assumed objective criterion that would significantly affect the substantive terms of the APA if the underlying conditions changed, whether or not the change is within the taxpayer's control. ... Consequently, the confidentiality provisions of the Act and the Convention limit the rights and powers of the CCRA to use and disclose information submitted in connection with an APA. ... CHANGE IN LAW OR TO THE CONVENTION If there is a change in law or to the Convention that modifies the Canadian federal income tax treatment of any matter covered by this APA, the new or amended law or the Convention will supersede this APA to the extent that it is inconsistent. 19. ...

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 ...

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. ...

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. ...

The sponsor of a convention hires an organizer to put on a convention that will be held in Manitoba. ... This convention is not an eligible tour package because it includes a convention facility and related convention supplies. ... Convention facility or related convention supplies packages- The sponsor of a convention hires an organizer to put on a convention that will be held in Manitoba. ...

This bulletin also provides information on changes to foreign visitor rebates and rebates available to tour operators and convention organizers as a result of harmonization. ... Foreign conventions (s 252.3, s 252.4) Rebates currently available to foreign convention organizers, sponsors and exhibitors for acquisition of convention facilities, short-term accommodation, or the acquisition or importation of related convention supplies will apply for HST purposes. For details, see the GST Memoranda Series, Chapter 27, Special Sectors: Tourism, Section 27.2, Conventions. ...

This bulletin also provides information on changes to foreign visitor rebates and rebates available to tour operators and convention organizers as a result of harmonization. ... Foreign conventions (s 252.3, s 252.4) Rebates currently available to foreign convention organizers, sponsors and exhibitors for acquisition of convention facilities, short-term accommodation, or the acquisition or importation of related convention supplies will apply for HST purposes. For details, see the GST Memoranda Series, Chapter 27, Special Sectors: Tourism, Section 27.2, Conventions. ...

Convention or treaty An income tax convention between Canada and a foreign jurisdiction (also referred to as a tax treaty or tax agreement). ... OECD Model Tax Convention OECD Model Tax Convention on Income and Capital. ... Treaty jurisdiction (or treaty partner) A country with which Canada has entered into a tax convention. ...

Organizations – Under Article XXI of the Canada–United States Tax Convention. ... Organizations – Under Article XXI of the Canada–United States Tax Convention Page details Date modified: 2015-07-09 ...