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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. ...

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 is not an eligible tour package because it includes a convention facility and related convention supplies. However, sponsors of foreign conventions, non-registered convention organizers and non-resident exhibitors may be eligible for other rebates under the FCTIP. ...

Convention A convention means a formal meeting or assembly that is not open to the general public. ... Convention facility A convention facility is any real property that is rented by the sponsor or organizer of a convention for use exclusively as the site for the convention. ... Organizer of a convention An organizer of a convention is a person who acquires the convention facility or related convention supplies and organizes the event for the sponsor. ...

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. ...

Income Tax Convention, Canada has the right to tax a resident of the United States who is providing services in Canada only if the person has a fixed base/PE in Canada. ... PE determinations In general, PE determinations should be made in light of the particular words of a treaty, the jurisprudence, and the Commentary on the OECD Model Tax Convention on Income and Capital (OECD Commentary), taking into consideration departures of the particular treaty from the OECD Model Tax Convention on Income and Capital (OECD Model). ... Income Tax Convention. Additionally, if a non-resident employer is determined not to have a PE in Canada its non-resident employees providing services in Canada are still subject to withholding under section 102 of the Income Tax Regulations (see the current version of information circular IC75-6R2, Required Withholding from Amounts Paid to Non-residents Providing Services in Canada). ...

For example, where an income tax deduction is not available for a third convention held within a year, ITCs may be claimed for expenses relating to that convention, but they are subject to the 50% limitation where an income tax deduction is not possible. ... For more information about this topic, including rebate eligibility criteria, please refer to the CCRA guide RC4036, GST/HST Information for the Travel and Convention Industry. ... What's New in Publications GST/HST Memoranda Series Memorandum 17.1.1    Products and Services of Investment Dealers Memorandum 17.14     Election for Exempt Supplies Memorandum 17.16    GST/HST Treatment of Insurance Claims Memorandum 19.5      Land and Associated Real Property GST/HST Guides RC4028 GST/HST New Housing Rebate RC4031 Tax Refund for Visitors to Canada RC4036 GST/HST Information for the Travel and Convention Industry RC4072 First Nations Tax (FNT) RC4081 GST/HST Information for Non-Profit Organizations RC4117 Tax Refund for Business Travel to Canada RC4231 GST/HST New Residential Rental Property Rebate Technical Information Bulletins B-087 GST/HST New Residential Rental Property Rebate B-088 Export Distribution Centre Program Current publications can be found on the CCRA Internet site at the following address: www.cra-arc.gc.ca/formspubs/topics/gst_hst-e.html. ...

For this reason, it is important that payers keep current with the status of tax conventions. b) Periodic or lump-sum? Many tax conventions will allow a different rate of tax depending if the payment is periodic or lump-sum. ... In such circumstances, payers must follow the definition of "periodic pension payment" found in paragraph 5 of the Income Tax Conventions Interpretation Act. c) Tax convention: The text as well as the status of each tax convention can be found on the Department of Finance's web site at: www.fin.gc.ca/treaties-conventions/in_force--eng.asp. ...

Senate Standing Committee on Banking Trade and Commerce April 25, 2013- Bill S-17, Tax Conventions Implementation Act, 2013. ... Follow-up requests for information (no committee appearance) House of Commons Standing Committee on Finance June 17, 2013- Bill S-17, an act to implement conventions, protocols, agreements, and a supplementary convention, concluded between Canada and Namibia, Serbia, Poland, Hong Kong, Luxembourg, and Switzerland, for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes (Tax Conventions Implementation Act, 2013). ...

GST/HST forms GST288 Supplement to Form GST189 and Form GST498 RC151 GST/HST Credit Application for Individuals Who Become Residents of Canada GST/HST Guides RC4036 GST/HST Information for the Travel and Convention Industry RC4070 Guide for Canadian Small Businesses RC4210; GST/HST Credit (Including related provincial credits and benefits) For the period from July 2008 to June 2009 RC4405 GST/HST Rulings- Experts in GST/HST Legislation GST/HST memoranda 3-3-1 Drop-Shipments  (revised) GST/HST policy statements P-184 Credit Card Expenses and the Registrant’s Use of Factors for Claiming Input Tax Credits (revised) P-237 The Acceptance of a Due Diligence Defence for a Penalty Imposed Under Subsection  280(1) of the Excise Tax Act for Failure to Remit or Pay an Amount When Required, and for a Penalty Imposed Under Section 280.1 for Failure to File a Return When Required (revised) GST/HST Info Sheets GI-046 Foreign Convention and Tour Incentive Program- Hunting and Fishing Packages GI-047 Taxidermy- Animal, Bird and Fish Mounts GI-048 Fertilizer and Pesticides All GST/HST, Excise Duty, and Excise Taxes and Special Levies publications can be found on the CRA Web site at www.cra.gc.ca/gsthsttech. ...