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29 articles · English

Source & edition
Country pairs / Canada / United Kingdom

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

Article 27 · Miscellaneous Rules

English · original source edition

Unreviewed · applicability unverified1978 base text; later amendments not included
Original & source
§
1. The provisions of this Convention shall not be construed to restrict in any manner any exclusion, exemption, deduction, credit or other allowance now or hereafter accorded by the laws of a Contracting State in the determination of the tax imposed by that Contracting State. 2. Where under any provision of this Convention any person is relieved from tax in a Contracting State on certain income and, under the law in force in the other Contracting State, that person is subject to tax in that other State in respect of that income by reference to the amount thereof which is remitted to or received in that other State, the relief from tax to be allowed under this Convention in the first-mentioned State shall apply only to the amounts so remitted or received. 3. Nothing in this Convention shall be construed as preventing Canada from imposing a tax on amounts included in the income of a resident of Canada by virtue of the provisions of section 91 of the Canadian Income Tax Act, so far as they are in force on the date of entry into force of this Convention, or have been modified only in minor respects, so as not to affect their general character. 4. The aggregate of the amount or value of the dividend and the amount of the tax credit referred to in paragraph 3(b) of Article 10 of this Convention shall be treated as a dividend for Canadian income tax purposes. 5. Each of the Contracting States will endeavour to collect on behalf of the other Contracting State such amounts as may be necessary to ensure that relief granted by this Convention from taxation imposed by that other State does not ensure to the benefit of persons not entitled thereto. However, nothing in this paragraph shall be construed as imposing on either of the Contracting States the obligation to carry out administrative measures of a different nature from those used in the collection of its own tax or which would be contrary to its public policy. 6. The competent authorities of the Contracting States may communicate with each other directly for the purpose of applying this Convention.
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 27; English; unreviewed source text, current applicability unverified; /editions/ca-gb-1978-as-made-html-v1/en/articles/article-27/

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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