Protocol Signed Between Canada and France

February 18, 2010

A Protocol amending the Tax Convention between the Government of the French Republic and the Government of Canada Signed on May 2, 1975, as Amended by the Protocol Signed on January 16, 1987 and as Further Amended by the Protocol Signed on November 30, 1995 (“Convention”), was signed on February 2, 2010, in Paris.

The Protocol will enter into force once Canada and the French Republic have notified each other of the completion of the procedures required for the bringing into force of this Protocol.  The provisions of the Protocol relating to Canadian withholding taxes will apply beginning on the first day of January of the first calendar year that begins after the Protocol has entered into force. For other Canadian taxes, its provisions will apply for taxation years that begin on or after the first day of January in the first calendar year after the Protocol has entered into force. A further notice advising of the entry into force of the Protocol will be communicated at that time.

The Protocol will extend the territorial coverage of the Convention to New Caledonia. Consistent with the Government’s policy announced in Budget 2007, the Protocol includes provisions reflecting the standard developed by the Organisation for Economic Cooperation and Development for the exchange of tax information.

The Protocol could facilitate the development of natural resources activity in New Caledonia. Extraction and processing activities that could potentially follow from successful exploration efforts could be associated with a variety of environmental impacts. All such potential activities will be subject to applicable environmental laws and regulations in New Caledonia.

For further information contact:

Tax Legislation Division
Phone: 613-369-4016