Australian Tax Treaties

Canadian Convention  

Canadian Protocol (No 1)  

ARTICLE 13  
Article 22 of the Convention shall be deleted and replaced by the following:

" ARTICLE 22 Source of Income  

(1)
Income, profits or gains derived by a resident of a Contracting State which, under any one or more of Articles 6 to 8 and 10 to 19, may be taxed in the other Contracting State, shall for the purposes of the law of that other Contracting State relating to its tax be deemed to be income from sources in that other Contracting State.

(2)
Income, profits or gains derived by a resident of a Contracting State which, under any one or more of Articles 6 to 8 and 10 to 19, may be taxed in the other Contracting State, shall for the purposes of Article 23 and of the law of the first-mentioned Contracting State relating to its tax be deemed to be income from sources in the other Contracting State. " .