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Question 7 It is very difficult to answer this question because we do not have specific rules other than that it must be for the purpose of administering a tax covered by the convention. ...

It was announced by the Department at the 1981 Canadian Tax Foundation Convention (Revenue Canada Round Table, Q. 12, “Treaty Shopping”- copy attached) that as a result of certain facts having come to the Department's attention it would no longer issue advance rulings on these arrangements. ...

Article XVIII of the Canada-Switzerland Income Tax Convention would apply to reduce the tax on the pension benefits from 25% to 15% of the benefit. ...

Le taux d'impôt est de 25% du montant brut des intérêts payés, à moins que ce taux soit réduit conformément aux dispositions d'une convention fiscale bilatérale. ...

Income Tax Convention (1980) unless the shares are described in subparagraph 3(b)(ii) thereof. ...

7 February 1991 Income Tax Severed Letter- Canada-Malta Income Tax Agreement Unedited CRA Tags Canada-Malta Income Tax Convention, Art. 28(4) Dear Sir: Re: Canada-Malta Income Tax Agreement, 1986 (the “Agreement”) This is in reply to your letter to the Canadian Embassy in Rome dated November 23, 1990, whereby you inquired concerning the application of paragraph (4) of Article 28 of the above-noted Agreement in respect of an offshore company registered under the Malta International Business Activities Act, 1988 that has waived in part the benefits of that Act by electing to pay tax at a rate higher than applicable to it under that Act but below the standard rate for companies owned by residents of Malta. ...

The Canada-United States Income Tax Convention (1980) does not provide for a reduction of Part XIII tax on such rental income. ...

15 January 1993 Income Tax Severed Letter 9238305- Withholding Tax—Barbados International Business Company Unedited CRA Tags 212(1)(b), Canada–Barbados Income Tax Convention Article XXX 923830 XXXXXXXXXX K. ...

21 June 1984 Income Tax Severed Letter A-9866 Unedited CRA Tags 212(1)(f), Canada-Germany Income Tax Convention Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

Accordingly, you are of the view that interest payments from Canco to the Swedish parent would not be subject to Part XIII withholding taxes because of paragraph 6 of Article 11 of the Canada-Sweden Income Tax Convention. ...