Canada: Tax-dispute arbitration procedures | KPMG | GLOBAL

Canada: Tax-dispute arbitration procedures, under income tax treaty with UK

Canada: Tax-dispute arbitration procedures

Canada and the United Kingdom have signed an agreement that clearly outlines procedures for the application of the arbitration provisions of the Canada-United Kingdom income tax treaty. The agreement provides for a clearly outlined process for the arbitration of tax disputes between the two nations.


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The agreement establishes rules and procedures under paragraphs 6 and 7 of Article 23 (Mutual Agreement Procedure) of the treaty, and concerns:

  • 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

The agreement will enter into force after the two countries have notified each other that the necessary domestic steps to bring the agreement into force have been completed. 

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