1. For the purposes of this agreement, “resident of a contracting state” means any person subject to state law because of his place of residence, place of residence, place of management or any other similar test. However, this concept does not include persons who, in that State party, are taxable only for income from sources of origin. 7. This article refers to the agreement between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland, signed in Ottawa on December 12, 1966, to avoid double taxation and prevent tax evasion on income and capital gains. 2. Notwithstanding paragraphs 1 and 7, the profits from the operation of vessels used primarily for the transport of persons or goods exclusively between places located in a contracting state may be taxed in that state. if, in both cases, conditions different from those allegedly made between independent companies are imposed or imposed between the two companies in their commercial or financial relations, all income, deductions, revenues or expenses that would have been charged to one of the companies for these conditions, but which were not taken into account because of these conditions , can be taken into account in calculating the profits or losses of this business and are taxed accordingly. 1.
This Convention does not affect the tax privileges of members of diplomatic or consular missions, in accordance with the general rules of international law or the provisions of specific agreements. 2. This article does not apply to the remuneration of services provided in the context of an activity carried out by one of the contracting states or by a political sub-direction or a territorial authority. 5. Notwithstanding other provisions of this agreement, payments of support and similar payments made in a contracting state to a resident of the other contracting state and who are the actual beneficiaries are taxable only in that other state. 6. The termination of the existing agreement in paragraph 5 of this article does not mark the end of the agreement between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland, signed in Ottawa on December 6, 1965, to avoid double taxation on certain income categories. This agreement ends with the entry into force of this Convention. The new agreements between the United Kingdom and Canada came into force on December 18, 2014 and intensify efforts by both governments to combat double taxation and the prevention of tax evasion. The United Kingdom has a double taxation agreement with Canada, that is, if you work in the United Kingdom and Canada and are treated as a resident, the treaty should avoid double taxation so that you do not be taxed twice on the same income.
Each double taxation agreement is different, although many follow very similar guidelines, although the details are different. (ii) for other Canadian taxes for fiscal year 1976 and subsequent years; 2. The competent authority referred to in paragraph 1 endeavours to resolve the matter by mutual agreement with the competent authority of the other State party where the objection appears justified and is unable to find an appropriate solution to resolve the case by mutual agreement with the competent authority of the other contracting State, so as not to avoid taxation in accordance with the convention. 2. When a company in a contracting state, when operating in the other contracting state through a stable establishment located there, the profits it should make are imputed, subject to paragraph 3, if it is a self-sustaining and self-sustaining enterprise engaged in the same or similar activities under identical or similar conditions and acting independently with the company of which it is a stable establishment.