Malaysia's Industrialization from 1950

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Canada Us Tax Agreement

8 Licence fees – Information relating to a franchise agreement 3 Notwithstanding the opening of the proceedings, the competent authorities may conclude a mutual agreement on the settlement of a case and close the proceedings. Accordingly, a data subject may at any time withdraw a request to the competent authorities for an agreement with the mutual agreement procedure (thus terminating the procedure). « 5. Where a person established in Canada and a shareholder of a U.S. company requests the competent authority of Canada to do so, the competent authority may agree, under conditions satisfactory to that competent authority, to apply the following rules for the purposes of taxation in Canada for the period during which the agreement is effective: (a) “relevant person” means the speaker of a case before a competent authority for the examination of that nature: (a) “data subject” to the speaker of a case before a competent authority for the purpose of examining such a case. ikel and, where appropriate, any other person whose tax liability to a Contracting State may be directly affected by a reciprocal agreement resulting from that consideration; (Note – A U.S. expat can take full advantage of the treaty waivers if they reside in Canada for at least 330 days a year, which is similar to the agreement the U.S. has with other counties.) 2. The competent authority of the State party to which the case has been submitted shall endeavour, if the objection appears to it to be justified and if it is unable to find a satisfactory solution itself, to resolve the case by mutual agreement with the competent authority of the other State party with a view to fiscal evasion which is not in conformity with the Convention. Unless the provisions of Article IX (related persons) apply, any agreement concluded shall be transposed into the domestic law of the Contracting States, notwithstanding any limitation of time or any other procedure, provided that the competent authority of the other State Party has been informed of the existence of such a case within six years of the end of the fiscal year to which the case relates. This Convention shall not affect the tax privileges of diplomatic representatives or consular agents, in accordance with the general rules of international law or the provisions of special agreements.

(b) the `date of entry` of a case is the earliest date on which both competent authorities have received the information necessary for the examination of the content of a mutually agreed agreement; 5. The competent authorities of the Contracting States may communicate directly with each other with a view to reaching an agreement within the meaning of the preceding paragraphs. If the above proposal is acceptable to your Government, I also propose that this note, which is authentic in English and French, and your reply Note, which reflects such acceptance, constitute an agreement between our two Governments, which will enter into force on the day of entry into force of the Protocol and will be annexed to the Convention as Annex A and is therefore an integral part of the Convention. 6 If the competent authorities have endeavoured, following a cartel procedure under this Article, but are unable to reach a full agreement in a case, the case shall be resolved by arbitration, as prescribed by paragraph 7 below and subject to the requirements of paragraph 7 below, as well as any rules or procedures agreed upon by States Parties through notes to be exchanged through diplomatic channels: implementation; if: 4. . . .

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