Tax treaties
Notices of developments
2024-2018
- Suspension of the Tax Agreement between Canada and Russia
(November 18, 2024)
- Tax Treaty Negotiations with Brazil
(October 24, 2018)
2017-2010
- Tax Treaty Negotiations with Switzerland
(June 7, 2017) - Tax Treaty Negotiations with Germany
(June 7, 2017) - Entry into force of the Agreement Concerning the Application of the Arbitration Provisions of the Canada-United Kingdom Tax Convention
(February 8, 2017)
- Exchange of Notes Concerning the Automatic Exchange of Information between Canada and Switzerland
(December 23, 2016) - Entry into Effect of the Tax Arrangement between the Trade and Economic Offices of Canada and Taiwan
(December 23, 2016) - Entry into Force of the Tax Convention between Canada and the State of Israel
(December 23, 2016) - Tax Convention Signed between Canada and Madagascar
(December 1st, 2016) - Tax Treaty Negotiations with San Marino
(October 7, 2016) - Tax Convention Signed between Canada and the State of Israel
(September 23, 2016) - Tax Arrangement Signed Between the Trade and Economic Offices of Canada and Taiwan
(January 18, 2016)
- Agreement Concerning the Application of the Arbitration Provisions of the Canada-United Kingdom Tax Convention
(November 26, 2015) - Entry into Force of the Protocol between Canada and Spain
(September 29, 2015) - Entry into Force of the New Tax Convention and Related Protocols between Canada and New Zealand
(June 26, 2015)
- Entry into Force of the Protocol Between Canada and the United Kingdom
(December 19, 2014) - Protocol Signed Between Canada and Spain
(November 18, 2014) - Second Protocol Signed Between Canada and New Zealand
(September 23, 2014) - Protocol Signed Between Canada and the United Kingdom
(July 21, 2014) - Entry into Force of the Information Exchange Agreement between Canada and the United States
(July 2, 2014) - Protocol Signed Between Canada and Belgium
(April 1st, 2014) - Information Exchange Agreement Signed Between Canada and the United States
(February 5, 2014)
- Entry Into Force of the Protocol Between Canada and France
(December 27, 2013) - Entry Into Force of the Protocol Between Canada and Barbados
(December 17, 2013) - Entry Into Force of the Protocol Between Canada and Luxembourg
(December 10, 2013) - Entry Into Force of the Agreement concerning the Interpretation of Article 25 of the Canada-Switzerland Tax Convention
(November 1st, 2013) - Entry Into Force of the Tax Convention Between Canada and Serbia
(November 1st, 2013) - Entry Into Force of the Tax Convention Between Canada and Poland
(October 30, 2013) - Entry Into Force of the Tax Agreement Between Canada and Hong Kong
(October 29, 2013) - Entry Into Force of the Protocol Between Canada and Austria
(July 24, 2013)
- Tax Convention Signed Between Canada and Hong Kong
(November 13, 2012) - Negotiation of an information exchange agreement with the United States
(November 8, 2012) - Entry Into Force of the Protocol Between Canada and Singapore
(August 8, 2012) - Agreement Concerning the Interpretation of Article 25 of the Canada-Switzerland Tax Convention
(July 27, 2012) - Tax Treaty Negotiations with Australia
(July 10, 2012) - Entry Into Force of the Tax Convention Between Canada and Colombia
(July 10, 2012) - Tax Convention Signed Between Canada and Poland
(May 14, 2012) - Protocol Signed Between Canada and Luxembourg
(May 8, 2012) - Tax Convention Signed Between Canada and New Zealand
(May 3, 2012) - Tax Convention Signed Between Canada and the Republic of Serbia
(April 30, 2012) - Second Protocol Signed Between Canada and Austria
(March 9, 2012)
- Entry into force of the Protocol Between Canada and Switzerland
(December 19, 2011) - Tax Treaty Negotiations with Israel
(December 2nd, 2011) - Protocol Signed Between Canada and Singapore
(November 30, 2011) - Entry Into Force of the Tax Convention Between Canada and Italy
(November 25, 2011) - Protocol Signed Between Canada and Barbados
(November 8, 2011) - Tax Treaty Negotiations with the United Kingdom
(September 1st, 2011) - Tax Treaty Negotiations with the Government of the Hong Kong Special Administrative Region of the People's Republic of China
(May 19, 2011) - Entry Into Force of the Tax Agreement Between Canada and Turkey
(May 6, 2011)
- Entry Into Force of the Tax Convention Between Canada and the Hellenic Republic
(December 16, 2010) - Tax Treaty Negotiations with China (PRC)
(November 4, 2010) - Protocol Signed Between Canada and Switzerland
(October 22, 2010) - Tax Convention Signed Between Canada and Namibia
(March 26, 2010) - Protocol Signed Between Canada and France
(February 18, 2010) - Tax Treaty Negotiations with Switzerland
(January 11, 2010)
2009-2002
- Tax Treaty Negotiations with New Zealand
(October 26, 2009) - Tax Treaty Negotiations with the Netherlands
(September 16, 2009) - Tax Agreement Signed Between Canada and the Republic of Turkey
(July 15, 2009) - Tax Convention Signed Between Canada and the Hellenic Republic
(July 3, 2009)
- Entry Into Force of the Tax Convention Between Canada and the Gabonese Republic
(December 31, 2008) - Tax Treaty Negotiations with Poland
(December 23, 2008) - Entry Into Force of the Protocol Amending the Tax Convention Between Canada and the United States
(December 15, 2008) - Tax Convention Signed Between Canada and the Republic of Colombia
(November 24, 2008)
- Tax Treaty Negotiations with Colombia
(September 7, 2007). - Tax Treaty Negotiations with Greece
(May 15, 2007). - Entry Into Force of the Tax Convention Between Canada and Mexico
(April 26, 2007). - Tax Treaty Negotiations with Spain
(April 4, 2007). - Entry Into Force of the Tax Convention Between Canada and Finland
(January 17, 2007). - Entry Into Force of the Tax Convention Between Canada and the Republic of Korea
(January 9, 2007).
- Tax Treaty Negotiations with Malaysia
(October 20, 2006). - Tax Convention Signed Between Canada and Mexico
(September 20, 2006). - Tax Convention Signed Between Canada and Finland
(September 20, 2006). - Tax Convention Signed Between Canada and the Republic of Korea
(September 5, 2006). - Entry Into Force of the Tax Convention Between Canada and Azerbaijan
(February 14, 2006). - Entry Into Force of the Tax Convention Between Canada and Armenia
(January 24, 2006). - Entry Into Force of the Tax Agreement Between Canada and Oman
(January 24, 2006).
- Tax Treaty Negotiations with Madagascar and Namibia
(October 13, 2005). - Entry Into Force of the Tax Convention Between Canada and Ireland
(April 20, 2005).
- Entry Into Force of the Tax Convention Between Canada and Romania
(December 14, 2004). - Entry Into Force of the Tax Convention Between Canada and Belgium
(October 12, 2004). - Tax Convention Signed Between Canada and Azerbaijan
(September 13, 2004). - Tax Treaty Negotiations with Finland
(August 23, 2004). - Tax Agreement Signed Between Canada and Oman
(July 13, 2004). - Tax Convention Signed Between Canada and Armenia
(July 12, 2004). - Entry Into Force of the Tax Convention Between Canada and the United Arab Emirates
(June 4, 2004). - Tax Treaty Negotiations with Singapore
(May 20, 2004). - Entry Into Force of the Tax Convention Between Canada and Venezuela
(May 11, 2004). - Entry Into Force of a Protocol Amending the Tax Convention Between Canada and the United Kingdom
(May 7, 2004). - Tax Convention Signed Between Canada and Romania
(April 16, 2004). - Tax Treaty Negotiations with the Republic of Korea
(February 12, 2004).
- Tax Treaty Negotiations with Serbia and Montenegro
(December 11, 2003). - Tax Convention Signed Between Canada and Ireland
(October 10, 2003). - Entry Into Force of the Tax Convention Between Canada and Senegal
(October 9, 2003). - Entry Into Force of the Tax Agreement Between Canada and Kuwait
(September 29, 2003). - Protocol Signed Between Canada and the United Kingdom
(May 14, 2003). - Tax Treaty Negotiations with Bolivia
(April 11, 2003). - Tax Treaty Negotiations with Cuba and Costa Rica
(March 31, 2003). - Entry Into Force of the Tax Convention Between Canada and Peru
(March 12, 2003). - Retraction -- Tax Convention Between Canada and Peru Not Yet in Force
(February 14, 2003).
- Entry into force of the Tax Convention Between Canada and Mongolia
(December 30, 2002) - Entry into force of the Tax Convention Between Canada and Norway
(December 30, 2002) - Entry into force of the Protocol Amending the Tax Convention Between Canada and Australia
(December 30, 2002) - Entry into force of the Tax Convention Between Canada and the Republic of Moldova
(December 30, 2002) - Tax Treaty Negotiations with Oman
(December 11, 2002) - Tax Convention Signed Between Canada and Gabon
(November 14, 2002) - Entry Into Force of the Tax Convention Between Canada and Slovenia
(September 6, 2002) - Tax Convention Signed Between Canada and Norway
(September 6, 2002) - Tax Convention Signed Between Canada and Moldova
(September 6, 2002) - Tax Convention Signed Between Canada and the United Arab Emirates
(September 6, 2002) - Entry into force of the Tax Convention Between Canada and the Czech Republic
(September 6, 2002) - Tax Convention Signed by Canada and Italy
(June 3, 2002) - Tax Convention Signed by Canada and Mongolia
(May 27, 2002) - Tax Convention Signed by Canada and Belgium
(May 24, 2002) - Entry Into Force of the Tax Agreement Between Canada and Germany
(April 4, 2002) - Tax Treaty Negotiations with Azerbaijan
(February 12, 2002) - Tax Agreement Signed by Canada and Kuwait
(January 28, 2002) - Protocol to the Tax Convention Between Canada and Australia Signed
(January 25, 2002) - Entry Into Force of the Tax Convention Between Canada and Ecuador
(January 8, 2002) - Entry Into Force of the Tax Agreement Between Canada and the Slovak Republic
(January 2, 2002)
Related resources
Multilateral tax treaties (2)
Canada is a party to two multilateral tax treaties: the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the Multilateral Instrument or MLI) and the Convention on Mutual Administrative Assistance in Tax Matters (MAAC). The MLI applies to modify many of Canada's bilateral tax treaties while the MAAC applies independently of Canada's bilateral tax treaties. Further information on these multilateral tax treaties may be obtained by clicking on the links provided below:
Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting
Background
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Multilateral Instrument or MLI) is a multilateral tax treaty that allows participating jurisdictions to adopt measures to prevent base erosion and profit shifting and to improve the dispute resolution process under their tax treaties. In general terms, base erosion and profit shifting (BEPS) refers to tax planning strategies used by multinational enterprises to exploit gaps and mismatches in the tax rules that apply between countries.
A unique aspect of the MLI is that it does not function in the same manner as an amending protocol. An amending protocol alters the text of a treaty. The MLI, on the other hand, is read alongside the treaties to which it applies modifying those treaties in their application.
Canada became a signatory to the MLI on June 7, 2017. The MLI was enacted by Parliament through the Multilateral Instrument in Respect of Tax Conventions Act, S.C. 2019, c.12. Canada subsequently deposited its instrument of ratification with the Depositary of the MLI (OECD Secretary General) on August 29, 2019 and the MLI entered into force for Canada, in accordance with Article 34 of the MLI, on December 1, 2019.
Which of Canada's tax treaties are modified by the MLI?
The MLI modifies Canada's tax treaties that are covered by the MLI. A tax treaty is covered by the MLI if both Canada and its treaty partner have listed the treaty for purposes of the MLI and have brought the MLI into force. Canada listed its tax treaties with 84 countries for the purposes of the MLI. Most of those countries are expected to become parties to the MLI and to list their tax treaty with Canada.
It should be noted that some of Canada's tax treaties will not be covered by the MLI. For example, the United States is not a signatory to the MLI and the Canada-United States Tax Convention was not included in Canada's listed treaties.
Canada's listed tax treaties for the purposes of the MLI
Impact of the MLI on Canada's covered tax treaties
The provisions of the MLI that apply to any particular covered tax treaty are a function of the terms of the MLI and on the compatibility of the choices that Canada and its treaty partner make under the MLI. Those choices are reflected in the notifications and reservations (MLI Positions) submitted to the Depositary of the MLI by Canada and its treaty partner.
The list of signatories and parties to the MLI, along with their MLI Positions, are available on the MLI Depositary (OECD) webpage :
MLI Signatories and Parties – MLI Positions
The MLI includes provisions that embody the treaty-related minimum standards established in the course of the OECD/G20 BEPS Project (namely those provisions on treaty abuse and the improvement of the dispute resolution process) and a number of optional provisions. A country or jurisdiction signing the MLI commits to meet the minimum standards (the MLI mirrors the requirements of the minimum standard by providing flexibility in the manner in which those standards are met). The optional provisions of the MLI (those provisions that are not part of the minimum standard) may be adopted by the parties to a covered tax agreement or a reservation may be made not to apply them.
For information on the choices made by Canada to apply specific provisions of the MLI, see:
Backgrounder to June 21, 2018 News Release
Entry into Effect
The provisions of the MLI will generally enter into effect with respect to any particular covered tax treaty:
- for taxes withheld at source - on the first day of the next calendar year that begins on or after the latest of the dates that the MLI enters into force for each of the parties to that treaty; and
- with respect to all other taxes - for taxes that are levied with respect to taxable periods beginning on or after the expiration of six calendar months from the latest of the dates that the MLI enters into force for each of the parties to that treaty.
With respect to any particular covered tax treaty, Canada's treaty partner may choose to modify the entry into effect provisions as they apply to that treaty partner (see, in this respect, Articles 35(2) and (3) of the MLI) or to reserve the right to delay the entry into effect provisions for both parties to the treaty to allow for the completion of its internal procedures (see, in this respect, Article 35(7) of the MLI). In addition, separate entry into effect provisions normally apply to modifications to the provisions of the mutual agreement procedure and to the MLI's arbitration provisions.
The entry into effect of the provisions of the MLI with respect to each covered tax treaty are described in the synthesised text to that treaty.
MLI synthesised texts of Canada's covered tax treaties
The Department of Finance is preparing texts of Canada's covered tax treaties that illustrate the impact of the MLI on those tax treaties (each referred to as a "synthesised text"). The synthesised text of a covered tax treaty will be posted under the name of Canada's treaty partner under the "List of countries" with tax treaties in force, which list is accessible at the following link:
Department of Finance: Tax treaties
Prior to posting a synthesised text, Canada's practice is to provide its treaty partner with the opportunity to review and comment on the synthesised text.
The synthesised texts are being provided for convenience of reference and are not a source of law. The applicable sources of law are the legal texts of the covered tax treaties and the MLI.
It should be noted that some of Canada's covered tax treaties may be modified by the MLI before the synthesised text for those treaties are posted. Therefore, in the absence of a synthesised text for a particular tax treaty, taxpayers and their advisors should take steps to determine if the MLI has entered into effect with respect to the relevant provisions of that treaty and to verify the manner in which the MLI applies. It should also be noted that the synthesised text of a covered tax treaty is generally based on the MLI Positions of Canada and its treaty partner at the time that Canada and its treaty partner deposit their respective instruments of ratification, acceptance or approval. These MLI Positions may subsequently be modified as provided under the MLI (e.g. by the withdrawal of a reservation) which may have an impact on the application of the MLI to the covered tax treaty.
Access to the MLI
The legal text of the MLI is available on the MLI (OECD) webpage :
in English: http://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-measures-to-prevent-BEPS.pdf
Convention on Mutual Administrative Assistance in Tax Matters
The Convention on Mutual Administrative Assistance in Tax Matters (MAAC) provides for administrative co-operation between jurisdictions in the assessment and collection of taxes for the purpose of combating tax avoidance and evasion. There are currently more than 140 jurisdictions that are participating in the MAAC. In Canada, the MAAC applies to Canadian taxes imposed by the Income Tax Act, as well as certain taxes imposed under the Excise Tax Act and the Excise Act, 2001. Canada became a party to the MAAC on March 1, 2014.
The Canada Revenue Agency relies on the MAAC to support a broad platform of information exchanges with other countries including the automatic exchange of information under Country-by-Country Reporting for large multinational enterprises and the exchange of financial account information under the Common Reporting Standard. The text of the MAAC, along with the declarations and reservations deposited by Canada in respect of the MAAC, are available at the following link:
Convention on Mutual Administrative Assistance in Tax Matters
Bilateral tax treaties (94)
Disclaimer: Tax treaties
The Department of Finance Canada assumes no responsibility for the accuracy or reliability of any income tax treaty available on this site. The treaties on this site have been prepared for convenience of reference only and have no official sanction.
For all purposes of interpreting and applying the law, users should consult the acts implementing the treaties as passed by Parliament, which are published in the annual Statutes of Canada. The Canada Treaty Series, published by the Department of Foreign Affairs and International Trade, could also be consulted.
Consult the Official sources: Where to find Canada's tax treaties page for details on locating the official versions. These publications are available in most public libraries.
List of Countries: A - E | F - J | K - O | P - T | U - Z
A - E
Algeria - Argentina - Armenia - Australia - Austria - Azerbaijan - Bangladesh - Barbados - Belgium - Brazil - Bulgaria - Cameroon - Chile - China (PRC)1 - Colombia - Croatia - Cyprus - Czech Republic - Denmark - Dominican Republic - Ecuador - Egypt - Estonia
F - J
Finland - France - Gabon - Germany - Greece - Guyana - Hong Kong - Hungary - Iceland - India - Indonesia - Ireland - Israel - Italy - Ivory Coast - Jamaica - Japan - Jordan
K - O
Kazakhstan - Kenya - Korea, Rep of - Kuwait - Kyrgyzstan - Latvia - Lithuania - Luxembourg - Madagascar - Malaysia - Malta - Mexico - Moldova - Mongolia - Morocco - Netherlands - New Zealand - Nigeria - Norway - Oman
P - T
Pakistan - Papua New Guinea - Peru - Philippines - Poland - Portugal - Romania - Russia - Senegal - Serbia - Singapore - Slovak Republic - Slovenia - South Africa - Spain - Sri Lanka - Sweden - Switzerland - Taiwan2 - Tanzania - Thailand - Trinidad & Tobago - Tunisia - Turkey
U - Z
Ukraine - United Arab Emirates - United Kingdom - United States - Uzbekistan - Venezuela - Vietnam - Zambia - Zimbabwe
Footnotes
1This Convention does not apply to Hong Kong.
2This is an Arrangement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income between the Canadian Trade Office in Taipei and the Taipei Economic and Cultural Office in Canada.
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