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June 6, 1946

TAXATION

AGREEMENT BETWEEN CANADA AND UNITED KINGDOM

Right Hon. L. S. ST. LAURENT (Acting Secretary of State for External Affairs): On behalf of the Secretary of State for External Affairs I wish to table copies of two agreements for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and with respect to duties on the estates of deceased persons between Canada and the United Kingdom, signed in London yesterday and being tabled in the House of Commons in London to-day. I understand that the Minister of National Revenue has a statement to make in regard to these agreements.
PC

John Bracken (Leader of the Official Opposition)

Progressive Conservative
Member File Biography @ PARLINFO

Mr. BRACKEN:

Has the minister copies immediately available?

Mr. ST. LAURENT: Copies have been mimeographed, and I have tabled three of them.

Topic:   TAXATION
Subtopic:   AGREEMENT BETWEEN CANADA AND UNITED KINGDOM
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Mr. COLD WELL@

Could they be printed in Votes and Proceedings so that they would be available? Are they too long for that?

Mr. ST. LAURENT: They are quite long, they are printed in the treaty series of external affairs and will be available in pamphlet form for the convenience of members of the house.

Topic:   TAXATION
Subtopic:   AGREEMENT BETWEEN CANADA AND UNITED KINGDOM
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Mr. COLD WELL@

Thank you.

Topic:   TAXATION
Subtopic:   AGREEMENT BETWEEN CANADA AND UNITED KINGDOM
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LIB

James Joseph McCann (Minister of National Revenue; Minister of National War Services)

Liberal
Member File Biography @ PARLINFO

Hon. J. J. McCANN (Minister of National Revenue):

I wish to make a statement with reference to the agreements which have just been tabled. The above mentioned agree-63260-140

ments, inter alia, affect, as to Canada, income tax, excess profits tax and succession duties; as to the United Kingdom, income tax, excess profits tax, national defence contributions, and estate duty.

Income tax, excess profits tax, national defence contributions:

(a) As to both countries, the industrial and commercial profits of a branch are to be initially taxed in the country of source, with credit for the tax so paid in the country of receipt, if the same profits are there subject to tax;

(b) Profits of ships and aircraft are taxed only in the country of residence of the taxpayer;

(c) Canada may deduct up to fifteen per cent at the source in respect of dividends, interest and other like income going to the United Kingdom;

The United Kingdom forgo their claim for surtax on income arising in the United Kingdom coming to Canada.

Each country will give credit for the taxes paid in the other;

(d) Both countries exempt copyright payments from taxation at the source, except rents and royalties in respect of motion picture films;

(e) The salaries of Canadian civil servants shall not be subject to tax in the United Kingdom, and vice versa;

(f) Canada will not tax a United Kingdom resident who earns income in Canada through personal presence in Canada if he is not in Canada over 183 days, and vice versa;

(g) Pensions and annuities arising in the United Kingdom, payable to residents of Canada, other than government pensions, shall be exempt from United Kingdom tax, and vice versa;

(h) Professors and teachers shall be exempt when temporarily in one. of the countries for periods not exceeding two years;

(i) A student or business apprentice of one of the countries while in the other country for educational or training purposes, shall be exempt from tax on payments for his maintenance from the country of his permanent residence;

(j) There shall be reciprocal exchange of information on request but for reason either may refuse to give the information;

(k) The agreement may be extended to colonies or protectorates imposing taxes substantially similar to those mentioned herein, but the subsequent cancellation of any such agreement does not affect the agreement between the United Kingdom and Canada;

Topic:   TAXATION
Subtopic:   AGREEMENT BETWEEN CANADA AND UNITED KINGDOM
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REV'I BED EDITION

Private Bills

(1) The duration of the agreement shall be three years, and may be terminated thereafter following a clear six months' notice and one year thereafter. The main parts as to succession duties, or estate duty as it is called in the United Kingdom, are: (a) The situs of the property substantially follows the general law of situs; (b) In the country of non-domicile the duty shall be based, as to rates and collections made, only on the assets having a situs in such country; (c) Credit shall be allowed by the country in which the deceased was domiciled of the tax paid on the assets situated in the other country, within certain limits; (d) Refund claims must be made within six months from the date of death; *(e) Information may be exchanged which is available under the laws of the two governments; (f) The duration of the agreement shall be for three years and may be terminated on sixty days' notice or longer.

THE GOVERNOR GENERAL

ANNOUNCEMENT OF ARRIVAL IN ENGLAND

On the order of motions:
LIB

Colin William George Gibson (Minister of National Defence for Air)

Liberal
Member File Biography @ PARLINFO

Hon. COLIN GIBSON (Minister of National Defence for Air):

Mr. Speaker, I am happy to inform the house that His Excellency the Governor General, accompanied by General Crerar, landed in England this morning by R.C.A.F. plane. They left Ottawa at four o'clock yesterday afternoon, and after a stop at Goose they arrived at Northolt airport at 10.26 this morning, eastern daylight saving time, within six minutes of the estimated time of arrival.

Topic:   THE GOVERNOR GENERAL
Subtopic:   ANNOUNCEMENT OF ARRIVAL IN ENGLAND
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PRIVATE BILLS

FIRST READINGS-SENATE BILLS

Bill No. 166, for the relief of Lillian Audrey Atkinson Jackson.-Mr. Casselman. Bill No. 167, for the relief of Bernard Cook. -Mr. MacLean. Bill No. 168, for the relief of Estelle R. Warhaft Slobod.-Mr. Maybank. Bill No. 169, for the relief of Alexander Fitz Ormonde Spooner.-Mr. Maybank. Bill No. 170, for the relief of Eleanor Williams.-Mr. Maybank. Bill No. 171, for the relief of Joseph Henri Veaudry.-Mr. Maybank. Bill No. 172, for the relief of Amelia Jezik Pascas.-Mr. Maybank. Bill No. 173, for the relief of Cyril Mackir -Mr. Maybank. Bill No. 174, for the relief of Carol Gordon Class Planche.-Mr. Maybank. Bill No. 175, for the relief of Eveline Richmond Sykes Lacoe.-Mr. Maybank. Bill No. 176, for the relief of Miriam Vine-berg Perel.-Mr. Maybank. Bill No. 177, for the relief of Paul Kraw-chuk.-Mr. Maybank. Bill No. 178, for the relief of Henry Arthur Creates.-Mr. Maybank. Bill No. 179, for the relief of Stephanie Tymchuk McLean.-Mr. Maybank. Bill No. 180, for the relief of Annie Spivack Prosterman.-Mr. Maybank. Bill No. 181, for the relief of Kenneth Edwin Morrison.-Mr. Maybank. Bill No. 182, for the relief of Almeda Mabel Hartry Ritchie. Mr. Boucher. Bill No. 183, for the relief of Margo Ismena Graydon Heubach.-Mr. Maybank. Bill No. 184, for the relief of Erika Gossen Tenzer. Mr. Maybank. Bill No. 185, for the relief of Isabel Green-shields Biggs.-Mr. Maybank. Bill No. 186, for the relief of Henri Edme Bernard.-Mr. Boucher. Bill No. 187, for the relief of Nellie Harrison Andersen.-Mr. Maybank. Bill No. 188, for the relief of Marie Irene Clementine Elizabeth Ash.-Mr. Maybank. Bill No. 189, for the relief of Alexander Grant.-Mr. Maybank. Bill No. 190, for the relief of Thomas Beach. -Mr. Casselman. Bill No. 191, for the relief of Fanny Miller Astrofsky.-Mr. Maybank. Bill No. 192, for the relief of Grace Ellen Rafter Munro.-Mr. Maybank.

QUESTIONS

(Questions answered orally are indicated by an asterisk.)

EXPLOSION AT BEDFORD BASIN NAVAL MAGAZINE, 1945

June 6, 1946