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  1. Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 - SI/2012-17
    Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011

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    The amended Article 10 shall therefore read as follows:

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    • 7 Notwithstanding any provision in this Convention, Canada may impose on the earnings of a company attributable to permanent establishments in Canada, tax in addition to the tax which would be chargeable on the earnings of a company incorporated in Canada, provided that the rate of such additional tax so imposed shall not exceed 5 per cent. For the purpose of this provision, the term earnings means the profits attributable to such permanent establishments in Canada (including gains from the alienation of property forming part of the business property, referred to in paragraph 2 of Article 13, of such permanent establishments) in accordance with Article 7 in a year and previous years after deducting therefrom:

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      The provisions of this paragraph shall also apply with respect to earnings from the alienation of immovable property in Canada by a company carrying on a trade in immovable property without a permanent establishment in Canada but only insofar as these earnings may be taxed in Canada in accordance with the provisions of Article 6 or paragraph 1 of Article 13.

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    • 4 The following paragraphs 6 and 7 shall be added to Article 24 of the Convention:

      • “6 Where,

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        any unresolved issues arising from the case shall be submitted to arbitration. The arbitration shall be conducted in a manner prescribed by the rules and procedures agreed upon by the Contracting States in an exchange of notes through diplomatic channels. These unresolved issues shall not, however, be submitted to arbitration if a decision on these issues has already been rendered by a court or administrative tribunal of either State. Unless a person whose taxation is directly affected by the arbitration decision does not accept that decision, it shall be binding on both Contracting States and shall constitute a resolution by mutual agreement under this Article.

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    • 1 The Contracting States shall notify each other in writing through diplomatic channels once they have satisfied their domestic requirements for the entry into force of this Protocol. This Protocol shall enter into force on the date of the later of these notifications and its provisions shall have effect:

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  2. Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011 - SI/2012-17
    Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Swiss Federal Council for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, Came into Force on December 16, 2011

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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 hereby required to take notice and to govern themselves accordingly.

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