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• 3 The existing taxes to which the Convention shall apply are in particular:

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  • (b) in the case of Canada, the taxes imposed by the Government of Canada under the Income Tax Act (hereinafter referred to as “Canadian tax”).

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• 2 For the purposes of this Convention, the term immovable property shall have the meaning which it has for the purposes of the relevant tax law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources; ships and aircraft shall not be regarded as immovable property.

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• 2 However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if a resident of the other Contracting State is the beneficial owner of the royalties the tax so charged shall not exceed:

  • (a) 5 per cent of the gross amount of the royalties if they are:

    • (i) copyright royalties and other like payments in respect of the production or reproduction of any literary, dramatic, musical or other artistic work (but not including royalties in respect of motion picture films nor royalties in respect of works on film or videotape or other means of reproduction for use in connection with television broadcasting); or

    • (ii) royalties for the use of, or the right to use, computer software or any patent or for information concerning industrial, commercial or scientific experience (but not including any such royalty provided in connection with a rental or franchise agreement);

• 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 Pensions, including social security payments, arising in a Contracting State and paid to a resident of the other Contracting State may also be taxed in the State in which they arise and according to the laws of that State, but in the case of periodic payments, the tax so charged shall not exceed 15 per cent of the gross amount of such periodic payments paid to the recipient in the calendar year concerned that exceeds twelve thousand Canadian dollars or its equivalent in Romanian currency.

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• 1 It is agreed that double taxation shall be avoided as follows:

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  • (b) in the case of Canada:

    • (i) subject to the existing provisions of the law of Canada regarding the deduction from tax payable in Canada of tax paid in a territory outside Canada and to any subsequent modification of those provisions — which shall not affect the general principle hereof — and unless a greater deduction or relief is provided under the laws of Canada, tax payable in Romania on profits, income or gains arising in Romania shall be deducted from any Canadian tax payable in respect of such profits, income or gains,

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• 2 The provisions of the Convention shall have effect:

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  • (b) in the case of Canada:

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    • (ii) in respect of other Canadian tax, for taxation years beginning on or after the first day of January in the calendar year following that in which the Convention enters into force.

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This Convention shall remain in force until terminated by a Contracting State. Either Contracting State may terminate the Convention after five years from the date on which the Convention enters into force provided that at least six months prior a written notice of termination has been given through diplomatic channels. In such event, the Convention shall cease to have effect:

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• (b) in the case of Canada:

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  • (ii) in respect of other Canadian tax, for taxation years beginning after the end of that calendar year.

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