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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Canada: Admissible & Inadmissible Taxes

The following Canadian taxes are admissible for credit in the UK:

a) Admissible for credit under the agreement

  • Income taxes imposed by the Government of Canada.
  • Tobacco Manufacturers’ Surtax.

b) Admissible for unilateral relief

The following taxes levied by the Canadian provinces are admissible for unilateral relief

Alberta

  • freehold mineral rights tax, provincial income tax.

British Columbia

  • provincial income tax,

 

  • mining tax,
  • logging tax,

         Manitoba

  • provincial income tax including the additional hospital services tax.

       New Brunswick -

  • provincial income tax,
  • mining tax.

Newfoundland

  • provincial income tax,
  • mining tax.

Nova Scotia

  • provincial income tax,
  • mining tax.

Ontario

  • provincial corporation tax on company profits,
  • provincial income tax,
  • mining tax,
  • corporate minimum tax (All claims for credit for this tax must be submitted to the Tax Treaty Team).

Prince Edward Island

  • provincial income tax.

Quebec

  • provincial corporation tax on company profits,
  • provincial income tax on individuals,
  • mining tax,
  • logging tax.

Saskatchewan

  • provincial income tax,
  • mining royalty tax.

c) Inadmissible

Federal taxes

  • taxes on capital,
  • large corporations tax (Federal) and any other taxes on capital,
  • place of business taxes,
  • petroleum and gas revenue tax,
  • taxes based on a percentage of premiums received by insurance companies.

Provincial taxes

Alberta

  • oil and gas conservation tax.