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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 23 · Mutual Agreement Procedure

English · original source edition

Unreviewed · applicability unverified1978 base text; later amendments not included
Original & source
§
1. Where a resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with this Convention, he may, without prejudice to the remedies provided by the national laws of those States, address to the competent authority of the Contracting State of which he is a resident an application in writing stating the grounds for claiming the revision of such taxation. 2. The competent authority referred to in paragraph 1 shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation not in accordance with the Convention. 3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Convention. In particular, the competent authorities of the Contracting States may reach agreement on: (a)the same attribution of profits to a resident of a Contracting State and its permanent establishment situated in the other Contracting State; (b)the same allocation of income between a resident of a Contracting State and any associated person provided for in Article 9.
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 23; English; unreviewed source text, current applicability unverified; /editions/ca-gb-1978-as-made-html-v1/en/articles/article-23/

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.

Page links are source references, not verified paragraph correspondence. Formatting and extraction errors may remain.

Noindex is not access control. This is a research preview, not a statement of authoritative or current law.

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

    Digest scope: retained online-source capture; no PDF binary verification

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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