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

February 8, 2017

The 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 Capital Gains (the "Agreement") entered into force on December 21, 2016. The Agreement was concluded through an exchange of notes dated July 27, 2015 and August 11, 2015.

The entry into force of this Agreement brings into effect paragraphs 6 and 7 of Article 23 (Mutual Agreement Procedure) 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 Capital Gains, as amended by Article XII of the Protocol signed at London July 21, 2014.

As set out in the Agreement, for cases that come under consideration of the competent authorities after December 21, 2016, paragraphs 6 and 7 of Article 23 have effect as of December 21, 2016. For cases under consideration of the competent authorities on December 21, 2016, paragraphs 6 and 7 of Article 23 also have effect as of December 21, 2016 except that the three-year period described in paragraph 6 of Article 23 shall begin on the later of December 21, 2016 and the date on which the information necessary to undertake substantive consideration for a mutual agreement has been received by the competent authorities of both Canada and the United Kingdom.

For further information contact:

Tax Legislation Division
Phone: (613) 369-4081

Please visit the Canada Revenue Agency's website for information on tax treaties and other information on international tax issues for business or individuals.