Bill C-10
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SUMMARY |
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The purpose of Parts 1 to 5 of this enactment is to implement income
tax conventions that have been signed with Sweden, Lithuania,
Kazakhstan, Iceland and Denmark.
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The treaties have two main objectives: the avoidance of double
taxation and the prevention of fiscal evasion. Since they contain
taxation rules that are different from the provisions of the Income Tax
Act, they become effective only if an Act giving them precedence over
domestic legislation is passed by Parliament.
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The conventions in this enactment are generally patterned on the
Model Double Taxation Convention prepared by the Organisation for
Economic Co-operation and Development.
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Part 6 of this enactment amends the Canada-Netherlands Income
Tax Convention Act, 1986 to implement a Protocol that amends the
income tax convention between Canada and the Netherlands. The
Protocol adds provisions concerning mutual assistance in the collection
of taxes and the elimination of the withholding tax on patent and
know-how royalties. A number of technical amendments are also made
to clarify existing provisions.
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Part 7 of this enactment amends the Canada-United States Tax
Convention Act, 1984 to implement a Protocol that amends the income
tax convention between Canada and the United States. The Protocol
provides that social security benefits will be taxable only in the
recipient's country of residence. It also limits the circumstances under
which one country may tax gains realized by a resident of the other
country on shares of a corporation.
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