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If the CRA and the vendor cannot agree as to whether the exemption of a particular tax convention applies, the vendor must provide the required payment or security before a certificate of compliance is issued. ... Income Tax Convention). These dispositions may be subject to the provisions of section 116. ... For more information, refer to the current version of IC71-17, Guidance on Competent Authority Assistance under Canada's Tax Conventions. ...

If the CRA and the vendor cannot agree as to whether the exemption of a particular tax convention applies, the vendor must provide the required payment or security before a certificate of compliance is issued. ... Income Tax Convention). These dispositions may be subject to the provisions of section 116. ... For more information, refer to the current version of IC71-17, Guidance on Competent Authority Assistance under Canada's Tax Conventions. ...

Contract governed by the Convention 11. In those cases where the contract between the parties is governed by the United Nations Convention on Contracts for the International Sale of Goods (Convention), the place where the tangible personal property is delivered or made available will have to be determined in accordance with the rules relating to delivery contained in the Convention rather than in accordance with the domestic law of any province. ...

Contract governed by the Convention 11. In those cases where the contract between the parties is governed by the United Nations Convention on Contracts for the International Sale of Goods (Convention), the place where the tangible personal property is delivered or made available will have to be determined in accordance with the rules relating to delivery contained in the Convention rather than in accordance with the domestic law of any province. ...

GST Not Applicable to Products or Services 1-30 Conventions- Foreign Description: Costs incurred by an insurer at a conference outside of Canada for Canadian personnel..Part 2- INVESTMENT PRODUCTS AND SERVICES Part 2- INVESTMENT PRODUCTS AND SERVICES Exempt Products and Services 2-1 Participation Income Description: Receives additional variable interest on a bond or mortgage loan in excess of a specified rate, calculated as a participating percentage of the financial results of the underlying security. ...

GST Not Applicable to Products or Services 1-30 Conventions- Foreign Description: Costs incurred by an insurer at a conference outside of Canada for Canadian personnel..Part 2- INVESTMENT PRODUCTS AND SERVICES Part 2- INVESTMENT PRODUCTS AND SERVICES Exempt Products and Services 2-1 Participation Income Description: Receives additional variable interest on a bond or mortgage loan in excess of a specified rate, calculated as a participating percentage of the financial results of the underlying security. ...

. ¶1.110 (formerly ¶16 of IT-478R2) has been modified to explain what is meant by a 115.1 agreement (an agreement to defer Canadian tax), to update the reference (Income Tax Folio S5-F2-C1, Foreign Tax Credit), and to add a reference to Information Circular 71-17R5, Guidance on Competent Authority Assistance under Canada’s Tax Conventions. ¶1.112 (formerly the second half of ¶17 of IT-478R2) has been amended to clarify the treatment of CCA recapture arising on the disposition of real or immovable property for which an election under section 216 has been previously made. ...

Generally, all means available within the legislation should be exhausted before remission relief is considered, that is, filing a notice of objection and/or an appeal, or requesting any recourse under a tax convention. ... Tax conventions 26. Is the income or gain realized on the disposition of property exempt from Part I tax under a tax convention? ... Is the vendor of the taxable Canadian property deemed to be a non-resident under a tax convention? ...

Generally, all means available within the legislation should be exhausted before remission relief is considered, that is, filing a notice of objection and/or an appeal, or requesting any recourse under a tax convention. ... Tax conventions 26. Is the income or gain realized on the disposition of property exempt from Part I tax under a tax convention? ... Is the vendor of the taxable Canadian property deemed to be a non-resident under a tax convention? ...

The arm's length principle is stated in paragraph 1 of Article 9 of the OECD Model Tax Convention: "Where... conditions are made or imposed between... two [non-arm's length] enterprises in their commercial or financial relations which differ from those which would be made between [arm's length] enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly. ... These rules: are generally found in Article IX of the relevant treaty; are often modelled after Article 9 of the OECD Model Tax Convention on Income and on Capital; and provide a framework in which adjustments to profits by one country's tax administration may be offset by a corresponding adjustment by the tax administration of another country. 216. ... The reader may refer to the most recent version of Information Circular 71-17, Requests for Competent Authority Consideration Under the Mutual Agreement Procedures in Income Tax Conventions. ...