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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Canada: Capital gains

Under its domestic law (TCGA92/S276 (7) ) and under the agreement (see Article 13(4) and 13(5) as amended by the 1985 amending agreement) the United Kingdom may tax any gains derived by a resident of Canada on the disposal of certain rights and assets connected with the exploration etc. for petroleum, natural gas and other related hydrocarbons in the United Kingdom and a designated area, certain shares deriving their value from such rights or assets and interests in partnerships and trusts whose assets consist principally of such assets or rights. These provisions do not apply where the shareholding or the interest in the partnership or trust is less than 10 per cent (see Article 13(6)).