DT4600 - Double Taxation Relief Manual: Guidance by country: Canada: Agreements in force

Title: 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

Signed: 8 September 1978

Statutory Instrument number: SI 1980 No. 709

Entered into force: 17 December 1980

Has effect:

  • in Canada, in respect of taxes withheld at source from 1 January 1976; in respect of other Canadian taxes from the 1976 taxation year
  • in the UK, in respect of income tax and capital gains tax, from 6 April 1976; in respect of corporation tax, from 1 April 1976

The text of the convention currently in force can be found at the following link: https://www.gov.uk/government/publications/canada-tax-treaties

The Convention has been modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI). The synthesised text of the Convention and the MLI can be found at the following link: https://www.gov.uk/government/publications/canada-tax-treaties

Protocols amending the 1978 convention

Title: Protocol Amending the 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

Signed: 15 April 1980

Statutory Instrument number: SI 1980 No. 1528

Entered into force: 17 December 1980

Has effect:

  • in Canada, in respect of offshore activities by Article 27A from January 1981, in respect of taxes withheld at source from 1 January 1976; in respect of other Canadian taxes from the 1976 taxation year
  • in the UK, in respect of income tax and capital gains tax, from 6 April 1976; in respect of corporation tax, from 1 April 1976 and offshore activities covered by Article 27A from 1 April 1981

Title: Protocol between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of Canada, further Amending the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains, signed at London on 8 September 1978 and Amended by a Protocol Signed at Ottawa on 15 April 1980

Signed: 16 October 1985

Statutory Instrument number: SI 1985 No. 1996

Entered into force: 23 December 1985

Has effect:

  • taxes withheld at source referred to in Articles 10 (Dividends), 11 (Interest) and 12 (Royalties) from 1 February 1986, in respect of Article 17 (Pensions & Annuities) from 6 April 1986; all other protocol provisions – Article 8 (Shipping & Air Transport), Article 13 (Capital Gains), Article 21 (Elimination of Double Taxation), Article 22 (Non-discrimination), Article 27 (Miscellaneous rules), Article 27A (Miscellaneous rules applicable to certain offshore activities) – In Canada from 1 January 1986 and in the UK from 1 April 1986

Title: Protocol Amending the 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, Signed at London on 8th September 1978, as Amended by the Protocol Signed at Ottawa on 15th April 1980 and as further Amended by the Protocol Signed at London on 16th October 1985

Signed: 7 May 2003

Statutory Instrument number: SI 2003 No. 2619

Entered into force: 4 May 2004

Has effect:

  • in Canada from 1 January 2005
  • in the UK, in respect of income tax and capital gains tax, from 6 April 2005; in respect of corporation tax, from 1 April 2005

Title: Protocol Amending the 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, Signed at London on 8th September 1978, as Amended by the Protocol Signed at Ottawa on 15th April 1980 and as further Amended by the Protocol Signed at London on 16th October 1985

Signed: 21 July 2014

Statutory Instrument number: SI 2014 No. 3274

Entered into force: 18 December 2014

Has effect:

  • in Canada from 1 January 2015
  • in the UK, in respect of income tax and capital gains tax, from 6 April 2015; in respect of corporation tax and withholding taxes from 1 April 2015

Title: Exchange of Notes on Arbitration

Signed: 11 August 2015

Statutory Instrument number: SI 2015 No. 2011

Entered into force: 21 December 2016

Has effect:

  • in the UK and Canada from 21 December 2016