Competent Authority Agreements and Notices

All jurisdictions

• Canadian Certificates of Residency not issued to fiscally transparent entities

Argentina

• Canada - Argentina agreement on Argentina’s Certification of Residency Form

Barbados

• Change to withholding tax rate on management fees in the Canada-Barbados Tax Agreement
• Canada-Barbados Tax Agreement – Agreement between Competent Authorities regarding Article XVI

Belgium

• Canada-Belgium Tax Convention - Agreement between Competent Authorities regarding Article 11 (Interest)

Chile

• Canada-Chile Tax Convention – Most Favoured Nation provision takes effect to reduce the tax rate on interest
• Changes to the withholding rates on interest and royalties and to the independent personal services Article in the Canada-Chile Tax Convention
• Change to withholding rate on dividends in the Canada-Chile Tax Convention

China

• Canada-China Income Tax Agreement - Agreement between Competent Authorities regarding paragraphs 3(a)(iv) and 3(b)(iv) of Article 11
• Canada-China Income Tax Agreement - Agreement between Competent Authorities regarding paragraph 3 of Article 11

Estonia

• Canada-Estonia Tax Convention – “Most Favoured Nation” provision takes effects to eliminate source-state taxation rights in respect of certain royalties

France

• Agreement between Competent Authorities regarding Article 12 (Royalties) of the Convention between Canada and France
• Canada-France agreement concerning a reduction in French taxes on certain payments made to Canadian mutual fund organizations
• Canada - France agreement concerning the exemption from French tax for certain payments made to pension plans

Germany

• Germany’s Federal Fiscal Court reverses a lower court decision by ruling that Germany may tax Canadian resident recipients of German social security pensions
• Additional information regarding the change to the taxation of German social security pensions
• Change to the taxation of social security pensions received from Germany by a resident of Canada - beginning 2005

Hong Kong

• Canada-Hong Kong Tax Agreement – Arrangement signed between competent authorities on the exchange of Country-by-Country Reports

Italy

• Canada-Italy Tax Convention - Agreement between Competent Authorities regarding Article 11 (Interest)
• How the new Canada-Italy Tax Convention affects the taxation of pension payments and social security benefits received

Korea

• Canada-Korea Income Tax Convention - Agreement between Competent Authorities regarding Article 11 (Interest)

Latvia

• Canada–Latvia Income Tax Convention: “Most Favoured Nation” provision takes effect to eliminate source-state taxation rights in respect of certain royalties

Lithuania

• Canada–Lithuania Income Tax Convention: “Most Favoured Nation” provision takes effect to eliminate source-state taxation rights in respect of certain royalties

Netherlands

• Canada-Netherlands Income Tax Convention - Agreement between Competent Authorities regarding withholding tax on closed fonds voor gemene rekening (FGR)

New Zealand

• Canada-New Zealand Income Tax Convention – Mode of Application regarding Article 10 (Dividends)

Norway

• Canada-Norway Tax Convention - Agreement between Competent Authorities regarding Article 10 (Dividends)
• Canada-Norway Tax Convention – Agreement between Competent Authorities regarding Article 11 (Interest)

Switzerland

• Agreement between Canada and Switzerland on refunding Swiss tax on Canadian collective investment vehicle
• Canada - Switzerland agreement concerning the recognition of social security arrangements for the purposes of Article 27(4) of the Canada-Switzerland Tax Convention
• Memorandum of Understanding between the Competent Authorities of Canada and Switzerland

United States

• Canada – U.S. Intergovernmental Agreement to Improve International Tax Compliance through Enhanced Exchange of Information - Arrangement between Competent Authorities regarding the First Home Savings Account
• Canada – U.S. Intergovernmental Agreement to Improve International Tax Compliance through Enhanced Exchange of Information - Arrangement between Competent Authorities for Deemed Compliant Financial Institutions
• Canada-U.S. Tax Convention – Arrangement signed between competent authorities on the exchange of Country-by-Country Reports
• Canada-U.S. Tax Convention - Agreement between Competent Authorities on the interpretation of Article VII (Business Profits)
• Arbitration Board Operating Guidelines - Canada - United States
• Memorandum of Understanding between The Competent Authorities of Canada and The United States of America [Regarding the application of the arbitration procedure under paragraphs 6 and 7 of Article XXVI (Mutual Agreement Procedure)]
• Guidelines on paragraph 6 of Article XXIX-A (Limitation on Benefits) of the Canada-U.S. Tax Convention

Vietnam

• Canada-Vietnam Income Tax Agreement - Agreement between Competent Authorities regarding Article 11 (Interest)

Other

• Changes to the Taxation of Social Security Benefits for Residents of Certain Countries with Which Canada has an Income Tax Convention