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Income Tax Conventions Implementation Act, 1996 ( 1997, c. 27 )
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Table of Contents (
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INCOME TAX CONVENTIONS IMPLEMENTATION ACT, 1996
SHORT TITLE
PART I: CANADA — RUSSIA INCOME TAX AGREEMENT
PART II: CANADA — SOUTH AFRICA INCOME TAX CONVENTION
PART III: CANADA — TANZANIA INCOME TAX AGREEMENT
PART IV: CANADA — INDIA INCOME TAX AGREEMENT
PART V: CANADA — UKRAINE INCOME TAX CONVENTION
SCHEDULE I
ARTICLE 1: Personal Scope
ARTICLE 2: Taxes Covered
ARTICLE 3: General Definitions
ARTICLE 4: Resident
ARTICLE 5: Permanent Establishment
ARTICLE 6: Income from Immovable Property
ARTICLE 7: Business Profits
ARTICLE 8: Income or profits from International Traffic
ARTICLE 9: Adjustments to Income
ARTICLE 10: Dividends
ARTICLE 11: Interest
ARTICLE 12: Royalties
ARTICLE 13: Gains from the Alienation of Property
ARTICLE 14: Income from Independent Personal Services
ARTICLE 15: Income from Dependent Personal Services
ARTICLE 16: Directors’ Fees
ARTICLE 17: Income of Artistes and Sportsmen
ARTICLE 18: Pensions and Similar Payments
ARTICLE 19: Income from Government Service
ARTICLE 20: Payments received by Students and Apprentices
ARTICLE 21: Other Income
ARTICLE 22: Capital
ARTICLE 23: Elimination of Double Taxation
ARTICLE 24: Non-Discrimination with respect to Taxation
ARTICLE 25: Mutual Agreement Procedure
ARTICLE 26: Exchange of Information
ARTICLE 27: Other Fiscal Privileges
ARTICLE 28: Special Provisions
ARTICLE 29: Entry into Force
ARTICLE 30: Termination
SCHEDULE II
ARTICLE 1: Personal Scope
ARTICLE 2: Taxes Covered
ARTICLE 3: General Definitions
ARTICLE 4: Resident
ARTICLE 5: Permanent Establishment
ARTICLE 6: Income from Immovable Property
ARTICLE 7: Business Profits
ARTICLE 8: Shipping and Air Transport
ARTICLE 9: Associated Persons
ARTICLE 10: Dividends
ARTICLE 11: Interest
ARTICLE 12: Royalties
ARTICLE 13: Capital Gains
ARTICLE 14: Independent Personal Services
ARTICLE 15: Dependent Personal Services
ARTICLE 16: Directors’ Fees
ARTICLE 17: Entertainers and Sportsmen
ARTICLE 18: Pensions and Annuities
ARTICLE 19: Government Service
ARTICLE 20: Students
ARTICLE 21: Other Income
ARTICLE 22: Avoidance of Double Taxation
ARTICLE 23: Non-Discrimination
ARTICLE 24: Mutual Agreement Procedure
ARTICLE 25: Exchange of Information
ARTICLE 26: Diplomatic Agents and Consular Officers
ARTICLE 27: Miscellaneous Rules
ARTICLE 28: Entry into Force
ARTICLE 29: Termination
SCHEDULE III
ARTICLE 1: Personal Scope
ARTICLE 2: Taxes Covered
ARTICLE 3: General Definitions
ARTICLE 4: Resident
ARTICLE 5: Permanent Establishment
ARTICLE 6: Income from Immovable Property
ARTICLE 7: Business Profits
ARTICLE 8: Shipping and Air Transport
ARTICLE 9: Associated Enterprises
ARTICLE 10: Dividends
ARTICLE 11: Interest
ARTICLE 12: Royalties
ARTICLE 13: Capital Gains
ARTICLE 14: Management and Professional Fees
ARTICLE 15: Independent Personal Services
ARTICLE 16: Dependent Personal Services
ARTICLE 17: Directors’ Fees
ARTICLE 18: Artistes and Athletes
ARTICLE 19: Pensions, Annuities and Social Security Payments
ARTICLE 20: Remuneration and Pension in respect of Government Service
ARTICLE 21: Students
ARTICLE 22: Other Income
ARTICLE 23: Capital
ARTICLE 24: Elimination of Double Taxation
ARTICLE 25: Non-Discrimination
ARTICLE 26: Mutual Agreement Procedure
ARTICLE 27: Exchange of Information
ARTICLE 28: Diplomatic Agents and Consular Officers
ARTICLE 29: Miscellaneous Rules
ARTICLE 30: Entry into Force
ARTICLE 31: Termination
SCHEDULE IV
ARTICLE 1: Personal Scope
ARTICLE 2: Taxes Covered
ARTICLE 3: General Definitions
ARTICLE 4: Residence
ARTICLE 5: Permanent Establishment
ARTICLE 6: Income from Immovable Property
ARTICLE 7: Business Profits
ARTICLE 8: Shipping and Air Transport
ARTICLE 9: Associated Enterprises
ARTICLE 10: Dividends
ARTICLE 11: Interest
ARTICLE 12: Royalties and Fees for Included Services
ARTICLE 13: Capital Gains
ARTICLE 14: Independent Personal Services
ARTICLE 15: Dependent Personal Services
ARTICLE 16: Directors’ Fees
ARTICLE 17: Artistes and Athletes
ARTICLE 18: Pensions
ARTICLE 19: Government Service
ARTICLE 20: Students and Apprentices
ARTICLE 21: Other Income
ARTICLE 22: Capital
ARTICLE 23: Elimination of Double Taxation
ARTICLE 24: Non-Discrimination
ARTICLE 25: Mutual Agreement Procedure
ARTICLE 26: Exchange of Information
ARTICLE 27: Diplomatic Agents and Consular Officers
ARTICLE 28: Miscellaneous Rules
ARTICLE 29: Entry into Force
ARTICLE 30: Termination
SCHEDULE V
ARTICLE 1: Personal Scope
ARTICLE 2: Taxes Covered
ARTICLE 3: General Definitions
ARTICLE 4: Resident
ARTICLE 5: Permanent Establishment
ARTICLE 6: Income from Immovable Property
ARTICLE 7: Business Profits
ARTICLE 8: Shipping and Air Transport
ARTICLE 9: Associated Enterprises
ARTICLE 10: Dividends
ARTICLE 11: Interest
ARTICLE 12: Royalties
ARTICLE 13: Capital Gains
ARTICLE 14: Independent Personal Services
ARTICLE 15: Dependent Personal Services
ARTICLE 16: Directors’ Fees
ARTICLE 17: Artistes and Sportsmen
ARTICLE 18: Pensions and Annuities
ARTICLE 19: Government Service
ARTICLE 20: Students
ARTICLE 21: Other Income
ARTICLE 22: Capital
ARTICLE 23: Elimination of Double Taxation
ARTICLE 24: Non-Discrimination
ARTICLE 25: Mutual Agreement Procedure
ARTICLE 26: Exchange of Information
ARTICLE 27: Members of Diplomatic Missions and Consular Posts
ARTICLE 28: Miscellaneous Rules
ARTICLE 29: Entry into Force
ARTICLE 30: Termination
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