Canada Double Taxation Agreement

3. The agreement between the Irish government and the Government of Canada, signed in Ottawa on October 28, 1954, on the prevention of double taxation and the prevention of income tax evasion, is denounced and extinguished for any period for which this agreement takes effect in accordance with paragraph 2 of this article. (ii) for other Canadian taxes for fiscal years beginning on the first day of January or after the first day of January, in the calendar year following the one in which ratification instruments are exchanged. (a) the recipient has been in the other territory for a period or period that was not greater than 183 days during the Canadian fiscal year or the Irish tax year concerned, and (a) that the provisions in the agreement of this decision were made with respect to the double taxation exemption with respect to income tax , corporate or corporate taxes and all taxes of a similar nature, collected by state or Canadian laws, and the Irish government and the Government of Canada, which wish to enter into an agreement to avoid double taxation and avoid tax evasion with respect to income taxes, have agreed as follows 2. resuscitation of agreements or agreements that have been abrogated by this agreement or by previous agreements between contracting governments. (a) at least 95%. gross revenue of the former corporation for each of its last three years of full taxation before the date the dividend was paid or credited (or, in the case of a corporation less than three years old for each full tax year before that date), received by the corporation or by non-residents who, or instead of paying dividends or interest , and provided that a life insurance company, which is based in Canada, which has a stable establishment in Ireland, does not affect, in this paragraph, the provisions of Irish law relating to the taxation of capital income of life insurance companies headquartered outside Ireland, provided they are applicable provisions (except to the extent that they were in accordance with article 2 of Article III of the agreement between the Irish Government and the Government signed in Ottawa on October 28, 1954, to avoid double taxation and avoid income tax evasion, signed in Ottawa on October 28, 1954. The date of the signing of this agreement in force. However, the above provisions are not considered as such that the aforementioned provisions of Irish law were regarded by the Oireachtas as governed by the provisions of the Irish State or were regarded as such by the Irish State. CONSIDERING that it is adopted by Section 361 (1) of the Income Tax Act 1967 (No. 6 of 1967) only when the government declares on behalf that double taxation exemption agreements have been concluded with the government of a territory outside the state with respect to personal income tax, surcharges or similar taxes. , imposed by the laws of the state or by the laws of that territory, and that these provisions should have the force of law, the provisions, notwithstanding a law, have the force of the law: 4.

When a company established in one of the territories derives profits or income from sources within the other territory. , the government of this other territory does not impose taxation on dividends distributed by the corporation to persons who are not established in that other territory, or on a tax in the nature of a tax on un distributed profits on the untributed profits of the company, since these dividends or untributed profits are fully or partially paid , the profits or revenues that are thus derived.

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