Australian Tax Treaties

Canadian Convention  

Canadian Protocol (No 1)  

ARTICLE 3  
Paragraphs (1) and (2) of Article 4 of the Convention shall be deleted and replaced by the following:

" (1)
Subject to paragraph (2), for the purposes of this Convention, a person is a resident of a Contracting State if that person is a resident of that State for the purposes of its tax. A Contracting State or any political subdivision or local authority thereof or any agency or instrumentality of any such State, subdivision or authority is also a resident of that State for the purposes of this Convention.

(2)
A person is not a resident of a Contracting State for the purposes of this Convention if the person is liable to tax in that State in respect only of income from sources in that State. " .