{
  "url": "https://openlegislation.uk/draft-double-taxation-relief-taxes-on-income-canada-order-2003/schedule/paragraph-3",
  "json_url": "https://openlegislation.uk/draft-double-taxation-relief-taxes-on-income-canada-order-2003/schedule/paragraph-3.json",
  "legislation": "ukdsi/2003/011046415X",
  "legislation_title": "The Double Taxation Relief (Taxes on Income) (Canada) Order 2003",
  "legislation_url": "https://openlegislation.uk/draft-double-taxation-relief-taxes-on-income-canada-order-2003",
  "path": "schedule/paragraph/3",
  "kind": "paragraph",
  "number": "3",
  "heading": null,
  "text": "Paragraph 5 of Article 10 of the Convention shall be deleted and replaced by the following:\n“5 The provisions of paragraphs 1 and 2 of this Article shall not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, or performs in that other State professional services from a fixed base situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed base. In such a case, the provisions of Article 7 or Article 14, as the case may be, shall apply.”",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukdsi/2003/011046415X/schedule/paragraph/3",
    "retrieved_at": "2026-10-30T15:25:11.319789+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}