2. The competent authority endeavours to resolve the matter by mutual agreement with the competent authority of the other contracting State where the objection appears to be well founded and is unable to find an appropriate solution to resolve the matter by mutual agreement with the competent authority of the other contracting State, in order to avoid taxation that is not in accordance with the agreement. Foreign tax credits are calculated by each country of origin or jurisdiction of origin, with separate calculations for corporate income taxes and non-business. The authorized foreign tax credit must not exceed Canadian tax, which would otherwise have to be paid for this income category. Foreign tax credits on property income (excluding real estate) must not exceed the 15 per cent lower value or retention rate of a corresponding tax agreement (for example. B, many Canadian contracts provide for an interest rate of 10 per cent on interest income) of foreign property income. Unused foreign credits cannot be carried forward to other years, but may be deducted if the foreign tax does not exceed the withholding tax rate set by a tax agreement between Canada and the country/jurisdiction that collected the tax. 1. This agreement does not affect the tax privileges of diplomatic or consular officials under the general rules of international law or the provisions of specific agreements. This page provides information on German double taxation conventions and other country-specific publications on double taxation conventions. You can view the original texts via our German website. A person may also be considered a resident of Canada for the entire calendar year in which that person has physically spent more than 182 days in Canada, unless he or she is able to apply the Tiebreaker residency rules in a tax treaty between Canada and the person`s country of residence to stop this rule. Double taxation agreements distribute tax duties among countries.
However, they do not create new revenue requirements. Where there are competing assets, they allocate tax legislation to only one of the countries concerned in order to avoid double taxation. 2. Referring to Article 3, paragraph 1, paragraph (f), and Article 5 and Article 8, ferries, deep-sea vessels or other vessels primarily transporting passengers or goods exclusively between premises located in a contracting state whose operation is not considered to have international traffic are understood; landing sites or places located in the contracting state and regularly used by these ships or ships in that establishment constitute a stable establishment in that state.