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  1. Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital signed on May 2, 1975, as amended by the Protocol signed on January 16, 1987 and as further amended by the Protocol signed on November 30, 1995 Came into Force on December 27, 2013 - SI/2014-56
    Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital signed on May 2, 1975, as amended by the Protocol signed on January 16, 1987 and as further amended by the Protocol signed on November 30, 1995 Came into Force on December 27, 2013

    Protocol Amending the Convention Between the Government of Canada and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital Signed on May 2, 1975, as Amended by the Protocol Signed on January 16, 1987 and as Further Amended by the Protocol Signed November 30, 1995

    [...]

    DESIRING to conclude a Protocol to amend further the Convention between the Government of Canada and the Government of the French Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, signed on May 2, 1975 as amended by the Protocol signed on January 16, 1987 and as further amended by the Protocol signed November 30, 1995 (hereinafter referred to as “the Convention”),

    HAVE AGREEDas follows:

    [...]

    • 1 Paragraphs 1 and 2 of Article 26 of the Convention shall be deleted and replaced by the following:

      • “1 The competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Convention or to the administration or enforcement of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States, insofar as the taxation thereunder is not contrary to the Convention. The exchange of information is not restricted by Articles 1 and 2.

      • 2 Any information received under paragraph 1 by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or the prosecution in respect of, the determination of appeals in relation to taxes, or the oversight of the above. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions.”

      • 3 In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting State the obligation:

        [...]

    [...]

    Paragraphs 1 and 2 of Article 28 of the Convention shall be deleted and replaced by the following:

    • “1 This Convention shall apply, with respect to France, to the European and Overseas Departments (Guadeloupe, Guyane, Martinique and Réunion) of the French Republic, to the Territorial Authority of Saint-Pierre-et-Miquelon as well as to New Caledonia.

    • 2 This Convention may be extended, either in its entirety or with any necessary modifications, to any other Overseas Territory of the French Republic which imposes taxes substantially similar in character to those to which the Convention applies. Any such extension shall take effect from such date and subject to such modifications and conditions, including conditions as to termination, as may be specified and agreed between the Contracting States in notes to be exchanged through diplomatic channels or in any other manner in accordance with their constitutional procedures.”

    [...]

    • 1 This Protocol shall remain in force as long as the Convention remains in force.

    • 2 The Contracting States shall be empowered, after the entry into force of the Protocol, to publish the text of the Convention as amended by the Protocols of January 16, 1987 and November 30, 1995 and by this Protocol.

    [...]


  2. Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital signed on May 2, 1975, as amended by the Protocol signed on January 16, 1987 and as further amended by the Protocol signed on November 30, 1995 Came into Force on December 27, 2013 - SI/2014-56
    Proclamation Giving Notice that the Protocol Amending the Convention between the Government of Canada and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital signed on May 2, 1975, as amended by the Protocol signed on January 16, 1987 and as further amended by the Protocol signed on November 30, 1995 Came into Force on December 27, 2013

    [...]

    Whereas, by Order in Council P.C. 2014-592 of May 15, 2014, the Governor in Council, pursuant to subsection 10(4) of An Act to implement conventions for the avoidance of double taxation with respect to income tax between Canada and France, Canada and Belgium and Canada and Israel, directed that a proclamation do issue giving notice of the entry into force on December 27, 2013 of the February 2, 2010 supplementary agreement, entitled Protocol Amending the Convention between the Government of Canada and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital signed on May 2, 1975, as amended by the Protocol signed on January 16, 1987 and as further amended by the Protocol signed November 30, 1995;

    Now know you that We, by and with the advice of Our Privy Council for Canada, do by this Our proclamation give notice of the entry into force on December 27, 2013 of the attached February 2, 2010 supplementary agreement, entitled Protocol Amending the Convention between the Government of Canada and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital signed on May 2, 1975, as amended by the Protocol signed on January 16, 1987 and as further amended by the Protocol signed November 30, 1995.

    [...]



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