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  1. Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income - SI/2016-44
    Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income

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    • 1 For the purposes of this Convention, unless the context otherwise requires:

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        • (i) 
          the land territory, internal waters and territorial sea, including the air space above these areas, of Canada;

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    • 5 Notwithstanding the provisions of paragraphs 1, 2, and 3, where an enterprise of a Contracting State performs services in the other Contracting State:

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      • (b) 
        for a period or periods exceeding in the aggregate 183 days in any 12-month period, and these services are performed for the same project or for connected projects through one or more individuals who are present and performing such services in that other State,

    the activities carried on in that other State in performing these services shall be deemed to be carried on through a permanent establishment of the enterprise situated in that other State, unless these services are limited to those mentioned in paragraph 7 which, if performed through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. For the purposes of this paragraph, services performed by an individual on behalf of one enterprise shall not be considered to be performed by another enterprise through that individual unless that other enterprise supervises, directs or controls the manner in which these services are performed by the individual.

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    • 8 The provisions of paragraph 7 shall also apply with respect to earnings derived from the alienation of immovable property in Canada by a company carrying on a trade in immovable property, whether or not it has a permanent establishment in Canada, but only insofar as these earnings may be taxed in Canada under the provisions of paragraph 1 of Article 13.

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    • 1 Each of the Contracting States shall notify the other Contracting State, through diplomatic channels, of the completion of the necessary domestic procedures for this Convention to enter into force in New Zealand and in Canada. This Convention shall enter into force on the date of the later of these notifications and its provisions shall have effect:

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    With reference to Article 17 of the Convention:

    It is understood that pensions paid by, or out of funds created by, the Government of New Zealand, or a political subdivision thereof to any individual in respect of services rendered to the Government of New Zealand or subdivision thereof, shall be taxable only in New Zealand. This paragraph only applies to pensions paid under a Government Superannuation Fund scheme or a National Provident Fund scheme to individuals who became members of one of these schemes prior to 1996.

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    Each of the Contracting States shall notify the other Contracting State, through diplomatic channels, of the completion of the procedures necessary to give this Protocol the force of law in New Zealand and in Canada, as the case may be. This Protocol shall enter into force on the date of the later of these notifications and its provisions shall have effect on the date that the Convention enters into force.

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  2. Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income - SI/2016-44
    Proclamation Giving Notice of the Entry into Force on June 26, 2015 of the Annexed Supplementary Convention intended to replace the Convention between Canada and New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income

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    TO ALL TO WHOM these presents shall come or whom the same may in any way concern,

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    Of all which Our Loving Subjects and all others whom these presents may concern are required to take notice and to govern themselves accordingly.

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