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HMRC internal manual

Double Taxation Relief Manual

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Double Taxation Relief Manual: Guidance by country: Canada: Agreements

The comprehensive agreement (SI 1980/709), as amended by a protocol (SI 1980/1528) entered into force on 18 December 1980. It has been amended by later protocols (SI 1985/1996 and SI 2003/2619), the latter of which is effective in the United Kingdom from 1 April 2005 for corporation tax and from 6 April 2005 for income tax and capital gains tax. In Canada, it is effective from 1 January 2005 for withholding tax on income derived by non- residents and other Canadian tax on income or gains.

If using the HMRC Intranet, these agreements and protocols and a consolidated version of the agreement currently in force can be viewed through the ‘New treaties/protocols in force’ link on the sidebar.

On the HMRC website, searching for ‘Treaties in force Canada’ will provide a link to the agreements and protocols.

Any problems concerning the application of the Convention for periods before the most recent protocol took effect should be referred to Tax Treaty Team, 100 Parliament Street, London SW1A 2BQ