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HMRC internal manual

Double Taxation Relief Manual

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

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.

Alberta -

oil and gas conservation tax.