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Protocol to the Tax Treaty between Canada and the U.K. has Entered into Force

22 December 2014

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Treaty Development

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Canada-United Kingdom

According to an announcement by the Canadian Department of Finance, the protocol to the 1978 income and capital tax treaty between Canada and the United Kingdom entered into force on 18 December 2014. The protocol is the fourth to amend the treaty, and includes multiple amendments. The main changes are as follows. OECD Model Standards Several articles are amended to be brought in line with OECD model standards, including: Article 7 Business Profits Article 23 Mutual Agreement Procedures (with an added arbitration provision) Article 24 Exchange of Information Article 24A Assistance in the Collection of Taxes (an addition) Dividends A...