This Convention will enter into force after each country has notified the other that the Convention has been ratified by its government. In Canada, the Convention will apply to tax withheld at source on amounts paid or credited to non-residents beginning on January 1 of the first calendar year after the Convention has entered into force and, for other taxes, for taxation years beginning on or after January 1 in the calendar year after the Convention has entered into force.
So, if the treaty is ratified in 2012, a corporation that has a March 31 year-end will be subject to the new treaty for its March 31, 2014 taxation year (i.e., the treaty will take effect on April 1, 2013).
For more information, contact your KPMG adviser.