On 21 July 2014, Canada and the U.K. signed a protocol to the 1978 income and capital tax treaty between the two countries. The protocol is the fourth to amend the treaty, and includes multiple amendments. Main changes are as follows.
OECD Model Standards
Several articles were amended to be brought in line with OECD model standards, including:
- Article 7 Business Profits
- Article 23 Mutual Agreement Procedures (with an added arbitration provision)
- Article 24 Exchange of Information
- Article…