Canada Tax News

Treaty between Canada and Malaysia – negotiations to start

17 December 2006

Treaty between Mexico and Canada – details

12 November 2006

Amendment to treaty between China (People's Rep.) and Canada

14 October 2006

Treaty between Korea (Rep.) and Canada signed

14 October 2006

Proposed legislation to eliminate double taxation of dividends paid by large Canadian corporations to Canadian individual shareholders

12 September 2006

Treaty between Finland and Canada – details

12 September 2006

Budget 2006 highlights

14 June 2006

The Competent Authorities of Canada and the United States have signed a memorandum of understanding (MOU) setting out the principles, guidelines and procedures to be followed in resolving factual disagreements in mutual agreement cases under the 1980 US-Canada income tax treaty. The MOU was signed on 23 December 2005 and follows the MOU signed on 3 June 2005 that formalized the mutual agreement procedure (MAP) for resolving cases of double taxation under the treaty. It also follows the announcement by the US Internal Revenue Service (IRS) and the Canada Revenue Agency (CRA) on 8 December 2005 that they had reached agreement on procedures for resolving factual disputes in the MAP process.

19 February 2006

French Guideline on treaty treatment of Canadian mutual funds in securities published

19 February 2006

Tax Court finds anti-avoidance rules not violated

6 December 2005

Tax Court of Canada applies tie-breaker rules in CanadaKorea (Rep.) tax treaty to determine residence status

16 October 2005

The protocol, signed on 3 September 2002 to the France and Quebec income tax treaty (entente fiscale) of 1 September 1987, entered into force on 1 August 2005. The purpose of this protocol is to harmonize the France-Quebec treaty with the modifications made in the protocol signed on 30 November 1995 to the France-Canada treaty.

16 October 2005

Revenue Agency releases transfer pricing memorandum on bundled transactions

21 September 2005

As from 1 January 2006, the 2003 income tax treaty, signed on 8 October 2003, will replace the 1966 income tax treaty.

1 May 2005

The new income and capital tax treaty between Canada and Romania, signed on 8 April 2004, entered into force on 31 December 2004. The new treaty generally applies from 1 January 2005.

19 January 2005