Agreement Concerning the Application of the Arbitration Provisions of the Canada-United Kingdom Tax Convention

November 26, 2015

An Agreement concerning the application of the arbitration provisions of the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital (the “Convention”) was concluded through an exchange of notes dated July 27, 2015 and August 11, 2015.

The Agreement establishes the rules and procedures for the application of the arbitration process under paragraphs 6 and 7 of Article 23 (Mutual Agreement Procedure) of the Convention. The Agreement includes substantive provisions on the decision-making process of the arbitration board, the precedential value of decisions rendered by the board, the type of issues that can be considered by the board, communication to and by the board, confidentiality, time periods and fees.

Canada and the United Kingdom will notify each other of the completion of their respective procedures that are necessary for the entry into force of the Agreement. The Agreement will enter into force and have effect on the date of the later of these notifications. The entry into force of the Agreement will bring into effect the provisions of paragraphs 6 and 7 of Article 23 of the Convention in accordance with the terms of the Agreement.

For further information contact:

Tax Legislation Division
Phone: (613) 369-4081

For information concerning the interpretation and application of Canada’s tax treaties, please contact the Canada Revenue Agency (CRA). Contact information is available on the CRA website. The CRA website has information concerning tax treaties and other information concerning international tax issues.