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Bill S-17

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S-17

First Session, Thirty-eighth Parliament,

53 Elizabeth II, 2004

SENATE OF CANADA

BILL S-17

An Act to implement an agreement, conventions and protocols concluded between Canada and Gabon, Ireland, Armenia, Oman and Azerbaijan for the avoidance of double taxation and the prevention of fiscal evasion

AS PASSED

BY THE SENATE
DECEMBER 8, 2004

Table of Contents

Table of Provisions

CANADA–GABON TAX CONVENTION

CANADA–IRELAND TAX CONVENTION

CANADA–ARMENIA TAX CONVENTION

CANADA–OMAN TAX AGREEMENT

CANADA–AZERBAIJAN TAX CONVENTION

CONVENTION BETWEEN THE GOVERNMENT OF CANADA AND THE GOVERNMENT OF THE GABONESE REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL

I. SCOPE OF THE CONVENTION

Persons Covered

II. DEFINITIONS

General Definitions

Permanent Establishment

III. TAXATION OF INCOME

Income from Immovable Property

Business Profits

Shipping and Air Transport

Associated Enterprises

Independent Personal Services

Dependent Personal Services

Directors’ Fees

Artistes and Sportspersons

Pensions and Annuities

Government Service

Students and Apprentices

IV. TAXATION OF CAPITAL

V. METHODS FOR PREVENTION OF DOUBLE TAXATION

Elimination of Double Taxation

VI. SPECIAL PROVISIONS

Non-Discrimination

Mutual Agreement Procedure

Exchange of Information

Members of Diplomatic Missions and Consular Posts

Miscellaneous Rules

VII. FINAL PROVISIONS

Entry into Force

CONVENTION BETWEEN THE GOVERNMENT OF CANADA AND THE GOVERNMENT OF IRELAND FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND CAPITAL GAINS

I. SCOPE OF THE CONVENTION

Persons Covered

II. DEFINITIONS

General Definitions

Permanent Establishment

III. TAXATION OF INCOME

Income from Immovable Property

Business Profits

Shipping and Air Transport

Associated Enterprises

Alienation of Property

Independent Personal Services

Dependent Personal Services

Directors’ Fees

Artists and Sportspersons

Pensions and Annuities

Government Service

Miscellaneous Rules Applicable to Certain Offshore Activities

IV. METHODS FOR PREVENTION OF DOUBLE TAXATION

Elimination of Double Taxation

V. SPECIAL PROVISIONS

Non-Discrimination

Mutual Agreement Procedure

Exchange of Information

Members of Diplomatic Missions and Consular Posts

Miscellaneous Rules

VI. FINAL PROVISIONS

Entry into Force

CONVENTION BETWEEN THE GOVERNMENT OF CANADA AND THE GOVERNMENT OF THE REPUBLIC OF ARMENIA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL

Persons Covered

General Definitions

Permanent Establishment

Income from Immovable Property

Business Profits

Shipping and Air Transport

Associated Enterprises

Independent Personal Services

Dependent Personal Services

Directors’ Fees

Artistes and Sportspersons

Government Service

Elimination of double taxation

Non-Discrimination

Mutual Agreement Procedure

Exchange of Information

Members of Diplomatic Missions and Consular Posts

Miscellaneous Rules

Entry into Force

AGREEMENT BETWEEN THE GOVERNMENT OF CANADA AND THE GOVERNMENT OF THE SULTANATE OF OMAN FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL

I. SCOPE OF THE AGREEMENT

Persons Covered

II. DEFINITIONS

General Definitions

Permanent Establishment

III. TAXATION OF INCOME

Income from Immovable Property

Business Profits

Shipping and Air Transport

Associated Enterprises

Income of Government and Institutions

Independent Personal Services

Income from Employment

Directors’ Fees

Artistes and Sportspersons

Pensions, Annuities and Similar Payments

Government Service

Students and Apprentices

IV. TAXATION OF CAPITAL

V. METHODS OF ELIMINATION OF DOUBLE TAXATION

Elimination of Double Taxation

VI. SPECIAL PROVISIONS

Mutual Agreement Procedure

Exchange of Information

Members of Diplomatic Missions and Consular Posts

Miscellaneous Rules

Protocol to the Agreement

VII. FINAL PROVISIONS

Entry into Force

PROTOCOL TO THE AGREEMENT BETWEEN THE GOVERNMENT OF CANADA AND THE GOVERNMENT OF THE SULTANATE OF OMAN FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL

CONVENTION BETWEEN THE GOVERNMENT OF CANADA AND THE GOVERNMENT OF THE REPUBLIC OF AZERBAIJAN FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL

I. SCOPE OF THE CONVENTION

Persons Covered

II. DEFINITIONS

General Definitions

Permanent Establishment

III. TAXATION OF INCOME

Income from Immovable Property

Business Profits

Shipping and Air Transport

Associated Enterprises

Independent Personal Services

Dependent Personal Services

Directors’ Fees

Artistes and Sportspersons

Pensions and Annuities

Government Service

IV. TAXATION OF CAPITAL

V. METHODS FOR ELIMINATION OF DOUBLE TAXATION

Elimination of Double Taxation

VI. SPECIAL PROVISIONS

Non-Discrimination

Mutual Agreement Procedure

Exchange of Information

Members of Diplomatic Missions and Consular Posts

VII. FINAL PROVISIONS

Entry into Force

PROTOCOL TO THE CONVENTION BETWEEN THE GOVERNMENT OF CANADA AND THE GOVERNMENT OF THE REPUBLIC OF AZERBAIJAN FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL