Canada-United Kingdom Tax Convention: Arbitration Provisions Coming SoonBy Robert Robillard - 1 December 2015
This blogpost originally appeared on rbrt.ca.
Department of Finance recently indicated:
“An Agreement concerning the application of the arbitration provisions of the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital (the “Convention”) was concluded through an exchange of notes dated July 27, 2015 and August 11, 2015.
The Agreement establishes the rules and procedures for the application of the arbitration process under paragraphs 6 and 7 of Article 23 (Mutual Agreement Procedure) of the Convention. The Agreement includes substantive provisions on the decision-making process of the arbitration board, the precedential value of decisions rendered by the board, the type of issues that can be considered by the board, communication to and by the board, confidentiality, time periods and fees.
Canada and the United Kingdom will notify each other of the completion of their respective procedures that are necessary for the entry into force of the Agreement. The Agreement will enter into force and have effect on the date of the later of these notifications. The entry into force of the Agreement will bring into effect the provisions of paragraphs 6 and 7 of Article 23 of the Convention in accordance with the terms of the Agreement.”
The complete text of the agreement is available here.
The library on Transfer Pricing in Canada is available here.
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