13 February 1990 Ruling HBW4125K3 F - Canada-Korea Income Tax Convention

February 13, 1990

Dear 19(1)

RE:  24(1)

We are writing in reply to your letter dated January 11, 1990, concerning the Canada- Korea Income Tax Convention and the status of the above-noted financial institution.  As the Minster of National Revenue has delegated the exercise of the competent authority function for the determination of such issues to the Director of Provincial and International Relations Division, your letter was forwarded to this Division for response.

24(1)

For purposes of paragraph 7 of article XI, paragraph 4 of the Protocol states that only those financial instrumentalities, other than the Export development Corporation of Canada and the Korea Exchange Bank specified and agreed to in letters exchanged between the competent authorities are eligible for exemption.  It is our understanding that the Protocol was added to ensure that only financial instrumentalities equivalent to our Export Development corporation are exempt.

In this regard, we are requesting more detailed information concerning the functions and responsibilities 24(1) would be helpful.  Any comments you may have concerning the intent of the Protocol are welcome.  We are enclosing, for your information, an Information Circular issued by the Export Development Corporation providing information concerning the operation of that company.

We will give this matter our utmost priority upon receipt of this information.  We look forward to hearing from you soon.

Yours sincerely,

C. SavageA/DirectorProvincial and International Relations Division

Enclosure

b.c.c.       R. McCoy Minister's Office

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