Schedule CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THE GOVERNMENT OF CANADA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND CAPITAL GAINS
The Government of the United Kingdom of Great Britain and Northern Ireland and the Government of Canada;
Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains;
Have agreed as follows:
- ARTICLE 1Personal Scope
- ARTICLE 2Taxes Covered
- ARTICLE 3General Definitions
- ARTICLE 4Fiscal Domicile
- ARTICLE 5Permanent Establishment
- ARTICLE 6Income from Immovable Property
- ARTICLE 7Business Profits
- ARTICLE 8Shipping and Air Transport
- ARTICLE 9Associated Enterprises
- ARTICLE 10Dividends
- ARTICLE 11Interest
- ARTICLE 12Royalties
- ARTICLE 13Capital Gains
- ARTICLE 14Professional Services
- ARTICLE 15Dependent Personal Services
- ARTICLE 16Artistes and Athletes
- ARTICLE 17Pensions and Annuities
- ARTICLE 18Government Service
- ARTICLE 19Students
- ARTICLE 20Estates and Trusts
- ARTICLE 21Elimination of Double Taxation
- ARTICLE 22Non-Discrimination
- ARTICLE 23Mutual Agreement Procedure
- ARTICLE 24Exchange of Information
- ARTICLE 25Diplomatic and Consular Officials
- ARTICLE 26Extension
- ARTICLE 27Miscellaneous Rules
- ARTICLE 28Entry into Force
- ARTICLE 29Termination