- 1
- 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.
- 2
- Articles 6 to 21 of the Convention shall not apply to non-resident-owned investment corporations as defined under section 133 of the Canadian Income Tax Act, or under any similar provision enacted by Canada after the signature of the Convention.
- 3
- The competent authorities of the States shall by mutual agreement settle the mode of application of Articles 10, 11, 12 and 21.
- 4
- The competent authorities of each of the States, in accordance with the practices of that State, may prescribe regulations necessary to carry out the other provisions of the Convention.
- 5
- The competent authorities of the States may communicate with each other directly for the purpose of applying the Convention.
