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Current CRA website

Guidance on Competent Authority Assistance Under Canada's Tax Conventions

Tax Convention, it is not entitled to the benefits under that Convention that require the person to be a resident of a contracting state. ... Tax conventions usually provide time limits for the taxpayer to present a case to the competent authority of taxation not in accordance with the convention. ... Tax Convention (1980) (the Convention) 64. The Convention contains certain specific provisions to relieve double taxation, as described below. ...
Current CRA website

Guidance on Competent Authority Assistance Under Canada's Tax Conventions

Tax Convention, it is not entitled to the benefits under that Convention that require the person to be a resident of a contracting state. ... Tax conventions usually provide time limits for the taxpayer to present a case to the competent authority of taxation not in accordance with the convention. ... Tax Convention (1980) (the Convention) 64. The Convention contains certain specific provisions to relieve double taxation, as described below. ...
Current CRA website

Questions and answers - Convention on Mutual Administrative Assistance in Tax Matters

What are the objectives of the Convention on Mutual Administrative Assistance in Tax Matters (the “Convention”)? ... When was the Convention established? Q3. Why was the Convention updated in 2010? ... When will the updated Convention come into force? Q1. What are the objectives of the Convention on Mutual Administrative Assistance in Tax Matters (the “Convention”)? ...
Current CRA website

Guidelines for Taxpayers Requesting Treaty Benefits Pursuant to Paragraph 6 of Article XXIX A of the Canada-U.S. Tax Convention

Article XXIX A Article XXIX A of the Convention CRA Canada Revenue Agency Competent Authority The Minister of National Revenue or the Minister's authorized representative the Convention The Convention Between Canada and the United States of America With Respect to Taxes on Income and on Capital Signed on September 26, 1980, as amended. ... United States of America Part I- Purpose and Scope of Article XXIX A of the Convention 3. Persons that are resident of the U.S. under Article IV of the Convention are entitled to the benefits of the Convention only if they satisfy the requirements set out in Article XXIX A. ...
Current CRA website

Competent Authority Assistance under Canada’s Tax Conventions

Canada’s tax conventions contain an article which is similar to Article 9 of the OECD Model Convention, which addresses transfer pricing adjustments. ... Specific issues under the Canada–United States Tax Convention (1980) (the Convention) Notification pursuant to Article IX (Related Persons) and Article XXVI (MAP) 79. ... The Convention (Canada-United States tax convention) does not have time limits for Articles XXVI and IX, but unlike all of Canada’s other treaties, the Convention does have a notification provision for both Articles XXVI and IX. 80. ...
Current CRA website

GST/HST registrants that pay or credit a rebate amount under the Foreign Convention and Tour Incentive Program

For rebates paid or credited to a sponsor or non-registered organizer of a foreign convention, you should obtain documentation to confirm that the event was a foreign convention. ... If it is later proved that the event is not a foreign convention, we will pay back the rebate amount that the eligible supplier paid or credited for the convention facility and/or related convention supplies. ... Example – How to report on your GST/HST return an amount that you paid or credited as a rebate payable to the sponsor of a foreign convention Example – How to report an amount paid or credited on account of a rebate payable to the sponsor of a foreign convention on your GST/HST return You are the organizer of a foreign convention held in Ontario and you are a GST/HST registrant. ...
Current CRA website

Applicable rate of part XIII tax on amounts paid or credited to persons in countries with which Canada has a tax convention

A tax convention is often referred to as a tax treaty, and the terms ‘tax convention’ and ‘tax treaty’ can be used interchangeably. ... Tax conventions ¶ 10. Negotiating new tax conventions between Canada and other countries and renegotiating existing conventions is an ongoing process. ... Some tax conventions contain an overriding provision that limits the reduction or elimination of tax provided for elsewhere in the convention. ...
Current CRA website

Foreign Convention and Tour Incentive Program - Tour Packages: What Is an Eligible Tour Package

Example 21 A non-resident person will attend a convention in Canada. The sponsor of the convention has booked a block of rooms at a hotel at a convention rate. ... Packages that include a convention facility or related convention supplies Packages that include a convention facility or related convention supplies are not eligible tour packages. Example 28 The sponsor of a convention hires an organizer to put on a convention that will be held in Manitoba. ...
Current CRA website

Foreign Convention and Tour Incentive Program - Tour Packages: What Is an Eligible Tour Package

Example 21 A non-resident person will attend a convention in Canada. The sponsor of the convention has booked a block of rooms at a hotel at a convention rate. ... Packages that include a convention facility or related convention supplies Packages that include a convention facility or related convention supplies are not eligible tour packages. Example 28 The sponsor of a convention hires an organizer to put on a convention that will be held in Manitoba. ...
Current CRA website

Foreign Convention and Tour Incentive Program

Foreign Convention and Tour Incentive Program Notices to reader The information on this page replaces the information in Guide RC4160, Rebate for Tour Packages, Foreign Conventions, and Non-Resident Exhibitor Purchases. ... In addition, a rebate under FCTIP continues to be available for certain expenses related to foreign conventions. ... Calculations Details Amounts Sales and other revenue (line 101) $2,000 GST/HST collected (line 103) $100 Adjustments (line 104) $0 Total GST/HST adjustments (line 105) $100 Input tax credits (line 106) $0 Adjustments (line 107) $0 Total ITCs / adjustments (line 108) $0 Net tax (line 109) $100 What to do if you choose to credit or pay the GST/HST rebate under FCTIP to your clients If you are registered for the GST/HST, you can choose to credit or pay the rebate amount payable under the FCTIP if one of the following applies to you: you supply eligible tour packages to: non-resident individuals, organizations or businesses (other than tour operators) non-resident tour operators you are an organizer of a foreign convention and you supply convention facilities and/or related convention supplies to the sponsor of the convention you are an operator of a convention facility who is not an organizer of the foreign convention and you supply convention facilities and related convention supplies to one of the following: a sponsor of a foreign convention an organizer of a foreign convention that is not registered for the GST/HST you are not an organizer of the foreign convention and you supply short-term accommodation or camping accommodation to one of the following: a sponsor of a foreign convention an organizer of a foreign convention that is not registered for the GST/HST Canadian suppliers cannot pay or credit the GST/HST and/or the QST to non-resident exhibitors. ...

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