Legal Updates January, 2015

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.

Wildeboer Dellelce LLP