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1Article 1 · Personal Scope2Article 2 · Taxes Covered3Article 3 · General Definitions4Article 4 · Fiscal Domicile5Article 5 · Permanent Establishment6Article 6 · Income from Immovable Property7Article 7 · Business Profits8Article 8 · Shipping and Air Transport9Article 9 · Associated Enterprises10Article 10 · Dividends11Article 11 · Interest12Article 12 · Royalties13Article 13 · Capital Gains14Article 14 · Professional Services15Article 15 · Dependent Personal Services16Article 16 · Artistes and Athletes17Article 17 · Pensions and Annuities18Article 18 · Government Service19Article 19 · Students20Article 20 · Estates and Trusts21Article 21 · Elimination of Double Taxation22Article 22 · Non-Discrimination23Article 23 · Mutual Agreement Procedure24Article 24 · Exchange of Information25Article 25 · Diplomatic and Consular Officials26Article 26 · Extension27Article 27 · Miscellaneous Rules28Article 28 · Entry into Force29Article 29 · TerminationPreamble · Title, publisher explanation and complete preambleSignature · Signature and authentic-language clauseFootnotes · Original Statutory Instrument references

29 articles · English

Source & edition
Country pairs / Canada / United Kingdom

Canada / United Kingdom · Canada–United Kingdom 1978 Convention: as-made source

Article 15 · Dependent Personal Services

English · original source edition

Unreviewed · applicability unverified1978 base text; later amendments not included
Original & source
§
1. Subject to the provisions of Articles 17 and 18, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a)the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned, and (b)the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and (c)the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State. 3. Notwithstanding the preceding provisions of this Article, remuneration in respect of an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the Contracting State in which the place of effective management of the enterprise is situated. 4. In relation to remuneration of a director of a company derived from the company the preceding provisions of this Article shall apply as if the remuneration were remuneration of an employee in respect of employment, and as if references to employer were references to the company.
Citation to select or copy

Canada / United Kingdom; SI 1980/709, Schedule, Convention signed 8 September 1978; official-hosted as-made electronic transcription contributed by Westlaw; edition 1978 base Convention as printed in SI 1980/709; later bilateral Protocols and MLI not incorporated; article 15; English; unreviewed source text, current applicability unverified; /editions/ca-gb-1978-as-made-html-v1/en/articles/article-15/

Disclaimers

Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.

Language switching retains source identifiers only. This is not reviewed legal or translational equivalence.

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Source & edition

SI 1980/709, Schedule, Convention signed 8 September 1978; official-hosted as-made electronic transcription contributed by Westlaw

  • Official online text · retained capture Official source website ↗

    SHA-256 c38e19bcf159401602fa427c92bca00168799d24329227cc0f591017fe84b68a

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Edition
1978 base Convention as printed in SI 1980/709; later bilateral Protocols and MLI not incorporated
Text available here
English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Signature
1978-09-08

Languages recorded in source metadata: English. This is not a promise of available text or a translation.

Edition notes and known limitations

Official HTML text capture, not Original PDF; human wording and current-law certification not claimed.

Block IDs are navigation aids, never invented legal paragraph numbers. Native extraction can flatten ordered-list styling; only printed source labels are retained.

Complete preamble, closing and all supplied integral protocol/notes are retained separately and searchable within this source.

Base source only. Known later bilateral Protocols (1980, 1985, 2003, 2014), 2015 arbitration notes and MLI modifications are not incorporated; see retained HMRC index for separate publications.

Canada Finance native requests timed out; retained official legislation.gov.uk HTML is the complete as-made Schedule, not a claimed current consolidation.

Source authority, text completeness and currentness still require human review.

Retained metadata & integrity record

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