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Canada Signs First Tax Treaty with Hong Kong - by Brian Mustard, Raphael Barchichat and Penny Woolford 

Global Tax Adviser


November 13, 2012


Brian Mustard and Raphael Barchichat
Montreal, International Corporate Tax


Penny Woolford
Toronto, International Corporate Tax


Canada signed its first tax treaty with Hong Kong on November 11, 2012. The treaty, which will govern Canadian taxes administered under the Income Tax Act, will restrict withholding taxes on dividends to 15% (or 5% for an entity that controls at least 10% of the voting power of the company paying the dividends), interest to 10% and royalties to 10%.

The treaty will enter into force after each country has notified the other that the treaty has been ratified by its government. In Canada, the treaty will generally apply to taxes that arise, or taxation years that begin, on or after January 1 of the calendar year following the year of entry into force. Hong Kong will consider the treaty to have taken effect for any year of assessment beginning after March 31 in the calendar year following the year of entry into force.


For more information, contact your KPMG adviser.






Information is current to November 13, 2012. The information contained in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG’s National Tax Centre at 416.777.8500.

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