DT Agreements: Canada - Income from a UK source paid to a resident of Canada
UK interest paid to a resident of Canada (Article 11)
UK interest paid to a resident of Canada who is the beneficial owner of the interest istaxable in the UK at 10%.
But full relief is available if the UK interest is paid in respect of a loan made,guaranteed or insured, or a credit extended, guaranteed or insured, by the ExportDevelopment Corporation (later Export Development Canada).
And there is no relief if the beneficial owner of the interest residentin Canada:
- is not subject to tax in Canada on the interest, and
- sells or makes a contract to sell the holding from which the interest is derived within three months of the date on which that owner acquired the holding.