Canada Us Tax Agreement

15 The fees and charges of the members of the arbitration body are set in accordance with the International Centre for Investment Litigation (ICSID) for arbitrators, as is the case on the day of the start of the arbitration, and are borne equally by the States Parties. All language translation costs are also borne equally by the States Parties. The meeting bodies, the related resources, the financial management, logistical support and the general administrative coordination of the procedure are provided at its own expense by the State Party whose competent authority has initiated the procedure of mutual agreement. All other costs are borne by the State party in its care. It is considered that the reference to Article XII (Redevances) The information provided under a franchise agreement generally relates only to information that governs the operation (whether by the payer or by another person) of the franchise or relates in any other way, and not to any other information relating to industrial, commercial or scientific experiments retained for resale or licence. (ii) the earliest date on which the agreement is (d) was reached by the two competent authorities; (e) If a person concerned does not accept the decision of an arbitration body, the decision constitutes a consensual resolution under this article and binds the two States parties in that case; and “5 If a person domiciled in Canada and a shareholder of a U.S. corporation asks Canada`s competent authority to do so, Canada`s competent authority may agree, subject to the conditions satisfactory to that authority, to apply the following provisions for taxation purposes in Canada during the period during which the agreement is effective. 8. Foreign residents of a State party Ownership of a corporation or other organization, reorganization, merger, split or other transactions and profits, profits or income related to such alienation are not recognized in that state for tax purposes, the competent authority of the other State party may, at the request of the person acquiring the estate, give its consent in order to avoid double taxation and to have conditions of double taxation. which are satisfactory for this competent authority to defer until that date and according to the terms provided by the agreement the recognition of the benefit, profit or income of these assets with respect to these assets for the purposes of taxation in that other state.

8 royalties – information related to the franchise agreement 4. Where, under paragraph 1, an estate, trust or other person (except one person or corporation) is established in the two contracting states, the competent authorities of the States agree to clarify the matter and determine the nature of the application of the agreement to that person. However, this information is deemed to be received only when the two competent authorities have received copies of all the documents that the person (s) concerned (s) has transmitted to one of the two States parties as part of the mutual agreement procedure. (b) the “date” of a case is the earliest date when the information necessary to examine the content of a mutual agreement was received by the two competent authorities; In all cases where the competent authorities have attempted but are unable to reach a full agreement in accordance with Article XXVI (procedure of mutual agreement) of the convention on the application of one or more of the following articles of the convention: IV (stay) (but only to the extent that it is a natural person), V (permanent exploitation), VII (corporate profits) , IX (related persons) and XII (royalties only) – to which Article IX could apply, or (ii) for a distribution of amounts between royalties that are taxable under paragraph 2 and royalties that are taxable in accordance with paragraph 3, a binding arbitration procedure is used to determine this claim, unless the competent authorities accept that it is in particular :