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HMRC internal manual

Double Taxation Relief Manual

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

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 from In Canada:In respect of taxes withheld at source, 1 January 1976In respect of other Canadian taxes, the 1976 taxation year In the United Kingdom, in respect of income tax and capital gains tax, 6 April 1976; in respect of corporation tax, 1 April 1976.

 

Protocols amending the 1978 agreement

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 from In Canada:

In respect of offshore activities covered by Article 27A, from January 1981

In respect of taxes withheld at source, 1 January 1976

In respect of other Canadian taxes, the 1976 taxation year

In the United Kingdom, in respect of income tax and capital gains tax, 6 April 1976; in respect of corporation tax, 1 April 1976.

In respect of 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 from In respect of taxes withheld at source referred to in Articles 10 (Dividends), 11 (Interest) and 12 (royalties), 1 February 1986

 

In respect of Article 17 (Pensions & Annuities), 6 April 1986

 

In respect of 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, 1 January 1986; In the UK, 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 from In Canada, 1 January 2005

In the UK:

In respect of income and capital gains tax, 6 April 2005

In respect of corporation tax, 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 from In Canada, 1 January 2015

 

In the UK:

 

In respect of income and capital gains tax, 6 April 2015

In respect of corporation tax, 1 April 2015

In respect of withholding taxes, 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 from In the UK and Canada, 21 December 2016