SolvedDT4600 | Double Taxation Relief Manual: Canada: Agreements in force
From HM Revenue & Customs · Double Taxation Relief Manual
Title: Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of Canada for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains
Signed: 8 September 1978
Statutory Instrument number: SI 1980 No. 709
Entered into force: 17 December 1980
Has effect:
in Canada, in respect of taxes withheld at source from 1 January 1976; in respect of other Canadian taxes from the 1976 taxation year
in the UK, in respect of income tax and capital gains tax, from 6 April 1976; in respect of corporation tax, from 1 April 1976
The text of the convention currently in force can be found at the following link: Canada tax treaties
The Convention has been modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI). The synthesised text of the Convention and the MLI can be found at the following link: Canada tax treaties
Protocols amending the 1978 convention
Title: Protocol Amending the Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of Canada for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains
Signed: 15 April 1980
Statutory Instrument number: SI 1980 No. 1528
Entered into force: 17 December 1980
Has effect:
in Canada, in respect of offshore activities by Article 27A from January 1981, in respect of taxes withheld at source from 1 January 1976; in respect of other Canadian taxes from the 1976 taxation year
in the UK, in respect of income tax and capital gains tax, from 6 April 1976; in respect of corporation tax, from 1 April 1976 and offshore activities covered by Article 27A from 1 April 1981
Title: Protocol between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of Canada, further Amending the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains, signed at London on 8 September 1978 and Amended by a Protocol Signed at Ottawa on 15 April 1980
Signed: 16 October 1985
Statutory Instrument number: SI 1985 No. 1996
Entered into force: 23 December 1985
Has effect:
taxes withheld at source referred to in Articles 10 (Dividends), 11 (Interest) and 12 (Royalties) from 1 February 1986, in respect of Article 17 (Pensions & Annuities) from 6 April 1986; all other protocol provisions – Article 8 (Shipping & Air Transport), Article 13 (Capital Gains), Article 21 (Elimination of Double Taxation), Article 22 (Non-discrimination), Article 27 (Miscellaneous rules), Article 27A (Miscellaneous rules applicable to certain offshore activities) – In Canada from 1 January 1986 and in the UK from 1 April 1986
Title: Protocol Amending the Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of Canada for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains, Signed at London on 8th September 1978, as Amended by the Protocol Signed at Ottawa on 15th April 1980 and as further Amended by the Protocol Signed at London on 16th October 1985
Signed: 7 May 2003
Statutory Instrument number: SI 2003 No. 2619
Entered into force: 4 May 2004
Has effect:
in Canada from 1 January 2005
in the UK, in respect of income tax and capital gains tax, from 6 April 2005; in respect of corporation tax, from 1 April 2005
Title: Protocol Amending the Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of Canada for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains, Signed at London on 8th September 1978, as Amended by the Protocol Signed at Ottawa on 15th April 1980 and as further Amended by the Protocol Signed at London on 16th October 1985
Signed: 21 July 2014
Statutory Instrument number: SI 2014 No. 3274
Entered into force: 18 December 2014
Has effect:
in Canada from 1 January 2015
in the UK, in respect of income tax and capital gains tax, from 6 April 2015; in respect of corporation tax and withholding taxes from 1 April 2015
Title: Exchange of Notes on Arbitration
Signed: 11 August 2015
Statutory Instrument number: SI 2015 No. 2011
Entered into force: 21 December 2016
Has effect:
in the UK and Canada from 21 December 2016