Who we are and how to contact us
Who we are
Where a person considers that the actions of Canada or a treaty partner result or may result in taxation not in accordance with a particular treaty, the person may request competent authority assistance. Assistance by the competent authority is generally provided under the mutual agreement procedure (MAP) article contained in Canada's tax treaties.
Canada's income tax treaties define the Canadian competent authority as the Minister of National Revenue or the Minister's authorized representatives.
What we do
The competent authority
- resolves double taxation cases;
- negotiates advanced pricing arrangements; and
- is responsible for exchange of information.
The competent authority also
- resolves issues concerning the application of tax treaties generally where specific taxpayers are not involved and interpretive issues involving treaty partners;
- considers the recognition of foreign pension plans allowed under certain treaties; and
- considers applications under paragraph 6, of Article XXIX A (Limitation on Benefits) in the Canada-US Tax Convention.
For more details, refer to IC71-17, Guidance on Competent Authority Assistance Under Canada's Tax Conventions.
For more information regarding double taxation cases and advance pricing arrangements, contact us at:
International and Large Business Directorate
Competent Authority Services Division
427 Laurier Avenue West
8th Floor, Enterprise Building
Ottawa ON K1A 0L5
Office of the Director – Competent Authority Services Division
Negus, Cindy – Director, 613-946-6022
Mutual Agreement Procedure – Advance Pricing Arrangement
Section 1: Nguyen, Tam – Manager, 613-941-9281
Section 2: Quinn, Dan – Manager, 613-952-6960
Section 3: Dukkipati, Sudha – Manager, 613-946-8897
Section 4: Busby, Brian – Manager, 613-946-6169
Mutual Agreement Procedure – Technical Cases
Boychuk, Daryl – Manager, 613-946-6085
Advance Pricing Arrangement - Mutual Agreement Procedure – Economic Analysis
Nayak, Govindaray – Chief Economist, 613-946-5162
For more information concerning the application of tax treaties where specific taxpayers are not involved, non-discrimination, recognition of foreign pension plans under treaties, and consideration of requests under paragraph 6, of Article XXIX A (Limitation on Benefits) in the Canada-US Tax Convention, contact us at:
Tax Treaties Section
Legislative Policy Directorate
Legislative Policy and Regulatory Affairs Branch
6th Floor, Tower A
Place de Ville
320 Queen Street
Ottawa ON K1A 0L5
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