| 19(1) | Jim Wilson |
| (613) 957-2063 | |
| HBW 6591-I-4 | |
| HBW 4125-I-7 |
February 15, 1990
Dear 19(1)
Re: Special Section for 24(1)
We are writing in follow-up to our telephone conversation on February 13, 1990, in which you requested confirmation as to the status of the above-noted institution under Article XI of the Canada - Italy Income Tax Convention.
Paragraph 3(c) of the Convention states that "notwithstanding the provisions of paragraph 2, interest arising in one of the Contracting States shall not be taxable in that State if the interest is paid in respect of a loan made, guaranteed or insured, or a credit extended, guaranteed or insured by any institution specified and agreed in letters exchanged between competent authorities of the Contracting State".
A competent authority has been reached in respect of 24(1). The agreement has effect for interest paid after August 26, 1988.
We trust you will find this to your satisfaction.
Yours sincerely,
C. SavageA/DirectorProvincial and International Relations Division
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