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  1. Income Tax Conventions Implementation Act, 1996 - S.C. 1997, c. 27 (SCHEDULE V : Convention Between Canada and Ukraine for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital)

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    • 3 Notwithstanding the provisions of paragraph 2:

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      • (c) interest arising in a Contracting State and paid to a resident of the other Contracting State which was constituted and is operated exclusively to administer or provide benefits under one or more pension, retirement or other employee benefits plans shall not be taxable in the first-mentioned State provided that:

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        • (ii) the interest is not derived from carrying on a trade or a business or from a related person.

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    • 4 The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience, and includes payments of any kind in respect of motion picture films and works on film, videotape, tape or other means of reproduction for use in connection with television or radio broadcasting.

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

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      • (c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).

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    • 3 For the purposes of paragraph 3 of Article XXII of the General Agreement on Trade in Services, the Contracting States agree that, notwithstanding that paragraph, any dispute between them as to whether a measure relating to a tax to which any provision of this Convention applies falls within the scope of this Convention may be brought before the Council for Trade in Services, as provided by that paragraph, only with the consent of both Contracting States.

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  2. Income Tax Conventions Implementation Act, 1996 - S.C. 1997, c. 27 (SCHEDULE II : Convention Between the Government of Canada and the Government of the Republic of South Africa for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income)

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    • 3 Notwithstanding the provisions of paragraph 2:

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      • (c) interest arising in a Contracting State and paid to a resident of the other Contracting State which was constituted and is operated exclusively to administer or provide benefits under one or more pension, retirement or other employee benefits plans shall not be taxable in the first-mentioned State provided that:

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        • (ii) the interest is not derived from carrying on a trade or a business or from a related person; and

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    • 3 The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright, patent, trade mark, design or model, plan, secret formula or process or other intangible property, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience, and includes payments of any kind in respect of motion picture films and works on film, videotape or other means of reproduction for use in connection with television.

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    • 2 Nothing in paragraph 1 shall be construed so as to impose on a Contracting State the obligation:

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      • (c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).

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    • 4 With respect to paragraph 3 of Article XXII of the General Agreement on Trade in Services, the Contracting States agree that, notwithstanding that paragraph, any dispute between them as to whether a measure relating to a tax to which any provision of this Convention applies falls within the scope of this Convention may be brought before the Council for Trade in Services, as provided by that paragraph, only with the consent of the Contracting States.

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  3. Income Tax Conventions Implementation Act, 1996 - S.C. 1997, c. 27 (SCHEDULE IV : Agreement Between the Government of Canada and the Government of the Republic of India for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital)

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    The provisions of this subparagraph shall also apply with respect to earnings from the disposition of immovable property situated 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 under the provisions of Article 6 or paragraph 1 of Article 13.

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

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      • (c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).

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    • 3 With respect to paragraph 3 of Article XXII of the General Agreement on Trade in Services, the Contracting States agree that, notwithstanding that paragraph, any dispute between them as to whether a measure relating to a tax to which any provision of this Agreement applies falls within the scope of this Agreement may be brought before the Council for Trade in Services, as provided by that paragraph, only with the consent of both Contracting States.

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  4. Income Tax Conventions Implementation Act, 1996 - S.C. 1997, c. 27 (SCHEDULE III : Agreement Between Canada and the United Republic of Tanzania for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital)

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    • 3 Notwithstanding the provisions of paragraph 2,

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      • (d) interest arising in a Contracting State and paid to a resident of the other Contracting State who was constituted and is operated exclusively to administer or provide benefits under one or more pension, retirement or other employee benefits plans shall not be taxable in the first-mentioned State provided that

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        • (ii) the interest is not derived from carrying on a trade or a business or from a related person.

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    • 3 The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright, patent, trade mark, design or model, plan, secret formula or process or other intangible property, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience (but does not include any amount paid as consideration for the right to exploit a mine, oil well or quarry or of any other place of extraction of natural resources), and includes payments of any kind in respect of motion picture films and works on film, videotape or other means of reproduction for use in connection with radio or television and gains arising in Tanzania derived from the sale or exchange of any right or property giving rise to such royalties.

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    • 4 For the purposes of paragraph 1(a), tax payable in Tanzania by a resident of Canada,

      • (a) in respect of profits attributable to a trade or business carried on by it in Tanzania,

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

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      • (c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).

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  5. Income Tax Conventions Implementation Act, 1996 - S.C. 1997, c. 27 (SCHEDULE I : Agreement Between the Government of Canada and the Government of the Russian Federation for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital)

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    • 4 The term “royalties” as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright, patent, trade mark, design or model, plan, secret formula or process or other intangible property, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience, and includes payments of any kind in respect of motion picture films and works on film, videotape or other means of reproduction for use in connection with television.

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    • 2 Nothing in paragraph 1 shall be construed so as to impose on a Contracting State the obligation:

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      • (c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).

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    • 2 Irrespective of the participation of the Contracting States in the General Agreement on Trade in Services (GATS), or in other international agreements, the Contracting States in their tax relations will be covered by the provisions of the present Agreement.

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