A Canada-UK agreement on arbitration provisions within their tax treaty is now in force.
This legally binding agreement establishes rules and procedures under paragraphs 6 and 7 of Article 23 (Mutual Agreement Procedure) of the Canada-UK tax treaty, and entered into force on December 21, 2016. The agreement, which was first signed on July 27, 2015, covers the following:
The procedures set out in the agreement will affect cases that come under the consideration of the competent authorities on or after December 21, 2016. However, for cases that come under consideration on December 21, 2016, the three-year period described in paragraph 6 of Article 23 shall begin on the later of December 21, 2016 and the date the competent authorities of both countries received the information necessary to undertake substantive consideration for a mutual agreement.
For more information, contact your KPMG adviser.
Information is current to February 14, 2017. The information contained in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's National Tax Centre at 416.777.8500