Canadian Tax Treaty and TIEA Update
The past year saw a number of announcements from the Canadian federal Department of Finance with respect to new and updated bilateral tax treaties and tax information exchange agreements (TIEAs) entered into between Canada and other countries. Generally speaking, tax treaties are entered into in order to avoid double taxation and to prevention fiscal evasion with respect to taxes on income and on capital. TIEAs, on the other hand, provide for the mutual exchange of tax information that is possessed by, or accessible to, the taxation authorities of either jurisdiction, in order to better administer and enforce taxation laws and to prevent international fiscal evasion. For a further discussion on TIEAs, please refer to our July 2010 Tax Law Update.
The following two tables list (in chronological order) Canada’s new and updated tax treaties and TIEAs from 2014.
|
Tax Treaties |
||
|
Country |
Status |
Date |
|
Belgium |
New Protocol to Treaty signed (not yet in force) |
April 1, 2014 |
|
United States |
New TIEA declared in force with respect to FATCA |
July 2, 2014 |
|
New Zealand |
New Protocol to Treaty signed (not yet in force) |
September 23, 2014 |
|
Spain |
New Protocol to Treaty signed (not yet in force) |
November 18, 2014 |
|
United Kingdom |
New Protocol to Treaty declared in force |
December 19, 2014 |
|
Tax Information Exchange Agreements |
||
|
Country |
Status |
Date |
|
Liechtenstein |
New TIEA declared in force |
January 27, 2014 |
|
British Virgin Islands |
New TIEA declared in force |
March 11, 2014 |
|
Bahrain |
New TIEA declared in force |
April 3, 2014 |
|
Uruguay |
New TIEA declared in force |
July 9, 2014 |
|
Brunei |
New TIEA declared in force |
December 4, 2014 |
This update is intended as a summary only and should not be regarded or relied upon as advice to any specific client or regarding any specific situation.
If you would like further information regarding the issues discussed in this update or if you wish to discuss any aspect of this commentary, please feel free to contact us.
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