# The Double Taxation Relief (Taxes on Income) (Canada) Order 2003, Paragraph 3


Paragraph 5 of Article 10 of the Convention shall be deleted and replaced by the following:
“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.”

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Source: https://www.legislation.gov.uk/ukdsi/2003/011046415X/schedule/paragraph/3 (the official version)
Page: https://openlegislation.uk/draft-double-taxation-relief-taxes-on-income-canada-order-2003/schedule/paragraph-3
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.