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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 3 · General Definitions

English · original source edition

Unreviewed · applicability unverified1978 base text; later amendments not included
Original & source
§
1. In this Convention, unless the context otherwise requires: (a)(i)the term “Canada” used in a geographical sense, means the territory of Canada, including any area beyond the territorial waters of Canada which is an area where Canada may, in accordance with its national legislation and international law, exercise sovereign rights with respect to the sea-bed and sub-soil and their natural resources; (ii)the term “United Kingdom” means Great Britain and Northern Ireland, including any area outside the territorial sea of the United Kingdom which in accordance with international law has been or may be hereafter designated, under the laws of the United Kingdom concerning the Continental Shelf, as an area within which the rights of the United Kingdom with respect to the sea-bed and sub-soil and their natural resources may be exercised; (b)the terms “a Contracting State” and “the other Contracting State” mean, as the context requires, the United Kingdom or Canada; (c)the term“person” comprises an individual, a company, any entity treated as a unit for tax purposes or any other body of persons; (d)the term “company” means any body corporate or any other entity which is treated as a body corporate for tax purposes; in French, the term “société” also means a “corporation” within the meaning of Canadian law; (e)the terms “enterprise of a Contracting State” and “enterprise of the other Contracting State” mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State; (f)the term “competent authority” means : (i)in the case of Canada, the Minister of National Revenue or his authorised representative;
§
(ii)in the case of the United Kingdom, the Commissioners of Inland Revenue or their authorised representative; (g)the term “tax” means United Kingdom tax or Canadian tax, as the context requires; (h)the term “national” means :— (i)in relation to the United Kingdom all citizens of the United Kingdom and Colonies, British Subjects under Sections 2, 13(1) or 16 of the British Nationality Act 1948 , and British Subjects by virtue of Section 1 of the British Nationality Act 1965, provided they are patrial within the meaning of the Immigration Act 1971, so far as these provisions 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; and all legal persons, partnerships, and associations deriving their status as such from the law in force in the United Kingdom;
§
(ii)in relation to Canada, all citizens of Canada and all legal persons, partnerships and associations deriving their status as such from the law in force in Canada. 2. As regards the application of the Convention by a Contracting State any term not otherwise defined shall, unless the context otherwise requires, have the meaning which it has under the laws of that Contracting State relating to the taxes which are the subject of the 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 3; English; unreviewed source text, current applicability unverified; /editions/ca-gb-1978-as-made-html-v1/en/articles/article-3/

Disclaimers

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

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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 ↗

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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.

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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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