SUMMARY

The main purpose of this enactment is to implement tax treaties - tax conventions or agreements and protocols thereto - that have been concluded with Kuwait, Mongolia, the United Arab Emirates, Moldova, Norway, Belgium and Italy. This enactment also amends the enacted text of three tax treaties.

Parts 1 to 4 of this enactment implement tax treaties with Kuwait, Mongolia, the United Arab Emirates and Moldova. This is the first time that Canada has concluded a tax treaty with any of these States.

Parts 5 to 7 of this enactment implement the most recent tax treaties with Norway, Belgium and Italy.

Parts 8 to 10 of this enactment correct errors in the English version of tax treaties with Vietnam, Portugal and Senegal, which are already enacted.

EXPLANATORY NOTES

Canada-Norway Income Tax Convention Act, 1967

Clause 7: Section 9 reads as follows:

9. Notice of the day the Convention comes into force and of the day the Convention ceases to be effective shall be given by proclamation of the Governor in Council published in the Canada Gazette.

Income Tax Conventions Implementation Act, 1998

Clause 10: (1) Paragraph 3 of Article 12 of the Agreement reads as follows:

3. The term ``royalties'' as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including payments of any kind in respect of motion picture films and works on film, tape or other means of reproduction for radio or television broadcasting), any patent, trade mark, design or model, plan, secret formula or process or other intangible property, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience.

Income Tax Conventions Implementation Act, 1999

Clause 11: (1) Paragraph 1 of Article 23 of the Convention reads as follows:

1. Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances, in particular with respect to residence, are or may be subjected. This provision shall, notwithstanding the provisions of Article 1, also apply to persons who are not residents of one or both of the Contracting States.