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Klaboe v. The Queen, 2007 TCC 239

[8] On May 23, 1969, numerous countries signed the Vienna Convention on the Law of Treaties (the Convention). Canada acceded to the Convention on October 14, 1970 and Barbados on June 24, 1971. The Convention itself came into force on January 27, 1980, i.e. a year before the Treaty entered into force. ...

93 C.M.TC - Q. 15 -- summary under Article 11

93 C.M.TC- Q. 15-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 The reductions in rates of withholding tax pursuant to the 1991 protocol to the Mexico Convention (arising when Mexico agrees to a lower rate in other treaties) do not take effect until the time that the lower rates of withholding tax take effect under the relevant tax treaty between Mexico and the third country, and only apply to the extent that the particular types of payment receive a lower rate of withholding tax under the other tax treaty. ...

4 September 1990 Memorandum (Tax Window, Prelim. No. 1, ¶1013) -- summary under Article 11

No. 1, ¶1013)-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 Where an individual who has Canadian source income which is fully taxable in Canada (e.g., employment income) but who is deemed by the tie-break rules in the Canada-Japan Income Tax Convention to be a resident of Japan, such interest income will be included in his income in the usual way, the resulting tax will be reduced to ensure that the effective rate of tax and the gross amount of the interest is limited to 10%. ...

5 May 2021 IFA Roundtable, Q.2 -- summary under Article 7(1)

After referencing its comments at 2019-0824551C6 on the TAP Committee responsibility for the PPT and noting that it was premature for any assessments to have been issued (the first deadline for NR4 filings for payments to which the PPT might apply was March 31, 2021; and the returns for the earliest 12-month taxation years to which the MLI could apply had a filing due date of November 30, 2021), CRA noted that it had received one pre-ruling consultation request: The underlying fact pattern of the request involved the payment of a dividend by a Canadian corporation (“Canco”) to a corporation residing in another jurisdiction (“NRCo”) with which Canada has a tax treaty (“Convention”). ... Canco requested confirmation that the Convention would apply to reduce the Canadian withholding tax rate of 25%, as provided in subsection 212(2), to a 5% withholding tax rate under the Convention, notwithstanding the MLI. … [T]he CRA will continue to contemplate the application of the GAAR to transactions undertaken primarily to secure a tax benefit afforded by a tax treaty. ...

Rémillard v. Canada (National Revenue), 2022 FC 338

These three bilateral conventions are based on the OECD Model Tax Convention on Income and on Capital 2017: OECD Publishing, 2019 [the Model Convention], which provides the following at article 26: The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Convention or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States, or of their political subdivisions or local authorities, insofar as the taxation thereunder is not contrary to the Convention. ... They all contain clause 26 from the Model Convention. [12] In Canada, the Minister (or authorized representative) is the designated “competent authority” for the application of these conventions. ... The Applicants’ interpretation is not consistent with the wording of the Convention (see also Update to Article 26 of the OECD Model Tax Convention and Its Commentary (Paris: OECD, 2012); as mentioned, the Model Tax Convention and its commentaries are relevant per Pacific Network and Blue Bridge at para 20). [156] She then lists the reasons for her conclusion. ...

IC 77-16R4 "Non-Resident Income Tax", para. 5 -- summary under Subsection 212(1)

Pending updates to IC76-12, Applicable rate of part XIII tax on amounts paid or credited to persons in countries with which Canada has a tax convention related to forms NR301, NR302, and NR303 IC76-12R6 "Applicable rate of part XIII tax on amounts paid or credited to persons in countries with which Canada has a tax convention" ...

Levett v. Canada (Attorney General), 2021 FC 295, aff'd 2022 FCA 117

The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Convention or to the administration or enforcement of the domestic laws concerning taxes covered by the Convention, insofar as the taxation thereunder is not contrary to the Convention. ... The Applicants’ interpretation is not consistent with the wording of the Convention (see also Update to Article 26 of the OECD Model Tax Convention and Its Commentary (Paris: OECD, 2012); as mentioned, the Model Tax Convention and its commentaries are relevant per Pacific Network and Blue Bridge at para 20). [162] Here, I am satisfied that the CRA pursued all reasonable domestic means available, given that: 1. ... As mentioned above, I conclude that the articles of the Convention should be given a broad and liberal interpretation. ...

Canada (Attorney General) v. Igloo Vikski Inc., 2016 SCC 38, [2016] 2 SCR 80

Given the Convention parties’ intention of creating a uniform classification scheme, the range of reasonable statutory interpretations in this context is narrow. ... Treaties and Other International Instruments International Convention on the Harmonized Commodity Description and Coding System, Can. ... Vienna Convention on the Law of Treaties, Can. T.S. 1980 No. 37, art. 31. ...

Canada (Minister of Citizenship and Immigration) v. Vavilov, 2019 SCC 65, [2019] 4 SCR 653

Vienna Convention on Consular Relations, Can. T.S. 1974 No. 25. Vienna Convention on Diplomatic Relations, Can. ... This statute incorporates into Canadian law aspects of the Vienna Convention on Diplomatic Relations, Can. ... I to the FMIOA , and the Vienna Convention on Consular Relations, Can. ...

2 December 2014 CTF Roundtable, Q. 7 -- summary under Article 29A

2 December 2014 CTF Roundtable, Q. 7-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A U.S. business was "substantial" for para. 3 purposes with 50% of revenues and assets and 10% of employees In what circumstances would CRA consider a US business to be "substantial" in relation to a Canadian business for purposes of Art. XXIX-A, para. 3 of the Canada–US tax Convention (the LOB Article)? CRA responded: For the purpose of determining whether the US business was "substantial" in relation to the Canadian operations in the context of [various] rulings, a number of factors were considered which included, but were not limited to: the relative amount of assets and revenues, number of employees involved in each jurisdiction, and in certain circumstances the relative amount of income and compensation expenses. … [S]ome of the more significant comparative ratios are summarized below: ...

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