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HMRC internal manual

International Manual

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DT Agreements: Canada - Income from a UK source paid to a resident of Canada

Other income paid to a resident of Canada

Article 20A of the United Kingdom/Canada Double Taxation Convention as introduced bySI2003/2619 and has effect in the United Kingdom for corporation tax for accountingperiods beginning on or after 1 April 2005 and for income tax and capital gains tax from 6April 2005.

It provides that items of income owned by a resident of Canada not dealt with in priorArticles of the Convention that arise in the United Kingdom, may be taxed in the UnitedKingdom.