The amending protocol of the Income Tax Treaty (1978) between Canada and United Kingdom has entered into force on 18th December 2014 that was signed on 21st July 2014. The protocol usually applies from the following dates:

Canada

  • 1st January 2015: for withholding and other taxes.

United Kingdom

  • 1st January 2015: for withholding taxes.
  • 1st April 2015: for corporate taxes.
  • 6th April 2015: for income and capital gains taxes.

Canada and United Kingdom

  • 18th December 2014: for provisions of changed article 23 (Mutual agreement procedure), article 24 and article 24A (Assistance in the collection of taxes).

The amended article 24A will not apply to revenue claims in respect of taxation years closing more than 5 years before the date on which this protocol enters into force.