The Double Taxation Relief and International Tax Enforcement (Canada) Order 2015

EXPLANATORY NOTE

(This note is not part of the Order)

The Schedule to this Order contains an Exchange of Letters (“the Agreement”) which supplements a convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of Canada for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains (“the Convention”).

The Convention is set out in the Schedule to the Double Taxation Relief (Taxes on Income) (Canada) Order 1980 (S.I. 1980/709) as amended by the arrangements set out in the Schedules to the Double Taxation Relief (Taxes on Income) (Canada) (No.2) Order 1980 (S.I. 1980/1528), the Double Taxation Relief (Taxes on Income) (Canada) Order 1985 (S.I. 1985/1996), the Double Taxation Relief (Taxes on Income) (Canada) Order 2003 (S.I. 2003/2619), and the Double Taxation Relief and International Tax Enforcement (Canada) Order 2014 (S.I. 2014/3274).

This Order brings the Agreement into effect.

Article 23 of the Convention (Mutual Agreement Procedure) was deleted and replaced by Article XII of the Schedule to The Double Taxation Relief and International Tax Enforcement (Canada) Order 2014. Paragraph 6 of Article 23 provides for arbitration to be conducted in the manner prescribed by the rules and procedures agreed upon by the Contracting States through an exchange of diplomatic notes. The Schedule to this Order contains that exchange of diplomatic notes.

Article 1 provides for citation.

Article 2 makes a declaration as to the effect and content of the Agreement.

The Agreement shall enter into force and have effect on the date of the later of the notifications by each country of the completion of its legislative procedures required to bring into force the Agreement.

The date of entry into force will, in due course, be published in the London, Edinburgh and Belfast Gazettes.

A Tax Information and Impact Note has not been prepared for this Order as it gives effect to a previously announced policy to enact a tax information exchange agreement.