On November 26, 2015 the Canadian Department of Finance published an Agreement concerning the application of the arbitration provisions of the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital (the “Convention”) was concluded through an exchange of notes dated July 27, 2015 and August 11, 2015.

According to a media release published by the Canadian Department of Finance in this respect, the Agreement establishes the rules and procedures for the application of the arbitration process under paragraphs 6 and 7 of Article 23 (Mutual Agreement Procedure) of the Convention. The Agreement includes substantive provisions on the decision-making process of the arbitration board, the precedential value of decisions rendered by the board, the type of issues that can be considered by the board, communication to and by the board, confidentiality, time periods and fees.

The media release also notes that Canada and the United Kingdom will notify each other of the completion of their respective procedures that are necessary for the entry into force of the Agreement. The Agreement will enter into force and have effect on the date of the later of these notifications. The entry into force of the Agreement will bring into effect the provisions of paragraphs 6 and 7 of Article 23 of the Convention in accordance with the terms of the Agreement.

Click here to be forwarded to the text of the Agreement Concerning the Application of the Arbitration Provisions of the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains, signed at London on September 8, 1978, as amended by the Protocol signed at Ottawa on April 15, 1980, by the Protocol signed at London on October 16, 1985, by the Protocol signed at London on May 7, 2003 and by the Protocol signed at London on July 21, 2014 as available on the website of the Canadian Department of Finance, which will open in a new window.

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