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

  • (a) the term “Madagascar” means the Republic of Madagascar, and when used in geographical sense, the territory of the Republic of Madagascar, including its territorial sea, contiguous zone and exclusive economic zone within which the sovereign rights and jurisdiction of the Republic of Madagascar may be exercised in accordance with international law. The sovereign rights of the Republic of Madagascar extend to the air space over the territorial sea as well as the corresponding sea bed, sub soil and the natural resources, without prejudice to a possible extension of the continental shelf of the Republic of Madagascar, in accordance with article 76 of the United Nations Convention on the Law of the Sea;

  • (b) the term “Canada”, used in a geographical sense, means:

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    • (ii) the exclusive economic zone of Canada, as determined by its domestic law, consistent with Part V of the United Nations Convention on the Law of the Sea of 10 December 1982 (UNCLOS); and

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• 1 Where a person considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with the provisions of this Convention, that person may, irrespective of the remedies provided by the domestic law of those States, submit to the competent authority of the Contracting State of which that person is a resident an application in writing stating the grounds for claiming the revision of such taxation. To be admissible, the said application must be submitted within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.

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The Convention shall enter into force on the date of the later of these notifications and its provisions shall thereupon have effect:

• (a) in Madagascar:

  • (i) in respect of withholding taxes, to sums payable on or after the first day of January in the calendar year following that in which the Convention enters into force; and

  • (ii) in respect of other taxes on income, 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;

• (b) in Canada:

  • (i) in respect of tax withheld at the source on amounts paid or credited to non-residents, on or after the first day of January in the calendar year following that in which the Convention enters into force; and

  • (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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