Australian Tax Treaties

Canadian Convention  

Canadian Protocol (No 1)  

ARTICLE 16  
A new Article 26A shall be added to the Convention immediately after Article 26 as follows:

" ARTICLE 26A Various Interests of Canadian Residents  
Nothing in this Convention shall be construed as preventing Canada from imposing a tax on amounts included in the income of a resident of Canada with respect to a partnership, trust, or controlled foreign affiliate, in which that resident has an interest. " .