6. Where difficulties or doubts about the interpretation or application of this agreement cannot be resolved by the competent authorities in accordance with the preceding paragraphs of this article, the case may be referred to arbitration if both the competent authorities and the subject consent and the subject agrees in writing to be bound by the decision of the arbitration body. In this case, the decision of the arbitration body is binding on both parties. The procedure is defined by an exchange of notes between the parties. The first tax agreement between Canada and the Hong Kong Special Administrative Region of the People`s Republic of China was signed on November 11, 2012, but has not yet entered into force. A notable feature of the treaty is the reduction of withholding tax. Comparing the treaty with other tax treaties recently signed by Canada and Canada`s old tax treaties, we can see a change in Canada`s section 23 policy. Section 23, paragraph 2, was added to a “inconsistent clause.” The effect of this clause is to exempt the relevant competent authorities from national statutes of limitations, which may provide for delays in the resolution of tax disputes. Therefore, the inclusion of the “indeterminate clause” in the contract should benefit residents of Hong Kong and Canada, since “non-treaty tax cases,” including legal and economic double taxation cases submitted to the relevant authorities within three years, should be resolved, regardless of national barriers to prescribing in the Canadian or Hong Kong tax system. Until recently, this “inconsistent clause” in the map section of Canada`s treaty network has historically been included only in the Canada-U.S. tax treaty. (ii) for other Canadian taxes for fiscal years beginning after the end of this calendar year.
3. The term “dividends” used in this article refers to income from shares, “Enjoyment” or “Play” shares, mining shares, founding shares or other rights other than debt securities participating in profits and income which, according to the laws of the party whose residents distribute the company, are subject to the same tax treatment as share income. 1 Regulation 5907 (11.2) does not, according to a foreign subsidiary, end in a country with which Canada has an agreement or comprehensive agreement to abolish double taxation, unless the foreign subsidiary is generally established in that country within the meaning of the convention or convention. 4. The competent authorities of the parties endeavour to resolve by mutual agreement any difficulty or doubt about the interpretation or application of this agreement. 1. The competent authorities of the contracting parties exchange information that is foreseeable for the implementation of the provisions of this agreement or for the management or application of the internal tax legislation of the parties relating to the taxes governed by this agreement, provided that the taxation of this agreement is not contrary to this agreement. The exchange of information is not limited by Article 1 (people concerned). This paragraph does not affect the corporation`s taxation on the profits on which the dividends are paid.