Protocol Signed Between Canada and the United Kingdom

July 21, 2014

A Protocol amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital was signed on July 21, 2014, in London.

The Protocol includes an exemption from withholding tax for payments of interest in respect of loans between persons who are dealing at arm’s length and a revised provision regarding exchange of tax information which reflects the standard developed by the Organisation for Economic Cooperation and Development. The Protocol also includes provisions on assistance in the collection of taxes and on arbitration.

Canada and the United Kingdom will notify each other of the completion of their respective procedures which are necessary for the entry into force of the Protocol. The Protocol will enter into force on the date of the later of these notifications and its provisions will have effect in accordance with Article XVI of the Protocol.

A further notice advising of the entry into force of the Protocol will be communicated at that time.

For further information contact:

Tax Legislation Division
Phone: 613-369-4016

For information concerning the interpretation and application of Canada’s tax treaties, please contact the Canada Revenue Agency (CRA). Contact information is available on the CRA website. The CRA website has information concerning tax treaties and other information concerning international tax issues.

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