International treaty

Canada: tax treaties

Tax treaties and related documents between the UK and Canada.

• From: HM Revenue & Customs
• Published: 25 January 2015
• Last updated: 15 November 2019 — See all updates

Documents

Synthesised text of the Multilateral Instrument and the 1978 Canada-UK Double Taxation Convention – in force

PDF, 209 KB, 29 pages

1978 Canada - UK Double Taxation Convention, amended by the 2014 Protocol - in force

PDF, 172 KB, 26 pages

2015 Canada - UK Exchange of Notes on Arbitration - in force

PDF, 270 KB, 11 pages

Details

Synthesised text of the Multilateral Instrument and the 1978 Canada-UK Double Taxation Convention - in force

The 1978 Canada-UK Double Taxation Convention has been modified by the Multilateral Instrument (MLI).

The modifications made by the MLI are effective in respect of the 1978 Canada-UK Double Taxation Convention for:

• taxes withheld at source on amounts paid or credited to non-residents, from 1 January 2020
• Corporation Tax, from 1 April 2021
• Income Tax and Capital Gains Tax, from 6 April 2021
• all other taxes levied by Canada, for taxable periods beginning on or after 1 June 2020

The Double Taxation Convention as amended by protocols signed on 15 April 1980, 16 October 1985 and 7 May 2003 and 21 July 2014, is effective in Canada from 1 January 1976

The convention is effective in the UK for:

• Petroleum Revenue Tax for any chargeable period on or before 1 January 1976
• Corporation Tax for any financial year beginning on or after 1 April 1976
• Income Tax and Capital Gains Tax for any year of assessment beginning on or after 6 April 1976
• development land tax for any realised development value accruing on or after 1 August 1976

The 2015 exchange of notes on arbitration was signed on 11 August 2015, entered into force on 21 December 2016 and takes effect in the UK and Canada from that date.

The arrangements set out in the 2015 Exchange of Notes add extra rules to the provisions on arbitration that were inserted into the Canada - UK Double Taxation Convention by the 2014 protocol.

Published 25 January 2015
Last updated 15 November 2019 + show all updates

1. 15 November 2019

   The 'Synthesised text of the Multilateral Instrument and the 1978 Canada-UK Double Taxation Convention - in force' has been added.

2. 5 January 2017

   2015 Canada/UK Exchange of Notes on Arbitration - not in force updated with new pdf.

3. 11 April 2016

   Added descriptive text: "The 2015 exchange of notes on arbitration was signed on 11 August 2015 and has not yet entered into force."

4. 25 January 2015

   First published.