Section 219.2

Administrative Policy

25 March 2015 External T.I. 2014-0560351E5 - Canada-Hong Kong Tax Agreement

Treaty with Hong Kong qualifies

Ss. 115.1(1), 116(5.01), 219.2, 219.3 and 248(1) – "tax treaty" refer to agreements Canada has with, or with the government of, another country. Do these references include the Agreement between the Government of Canada and the Government of the Hong Kong Special Administrative Region of the People's Republic of China (the "Canada-Hong Kong Tax Agreement")? In indicating that indeed "the condition that the Canada-Hong Kong Tax Agreement be an agreement with, or with the government of, another country is satisfied," CRA stated:

Pursuant to Article 151 of The Basic Law of the Hong Kong Special Administrative Region ("HKSAR") of the People's Republic of China, authority to conclude and implement agreements with foreign states… in appropriate fields is delegated to the HKSAR. …The Canada-Hong Kong Tax Agreement is…one such agreement.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 219.3 Treaty with Hong Kong qualifies 123
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - “Tax Treaty” Treaty with Hong Kong qualifies 123