8 May 1990 Income Tax Severed Letter ACC9115 - Canada-Switzerland Income Tax Convention

By services, 22 July, 2022
Official title
Canada-Switzerland Income Tax Convention
Language
English
Document number
Citation name
ACC9115
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
657414
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-05-08 08:00:00",
"field_tags": []
}
Main text

19(1)

                               HBW 4125-S2
                               David R. Senécal
                               (613) 957-2074

May 8, 1990

Dear 19(1)

Pursuant to paragraph 4 of Article XXIV of the Canada-Switzerland Income Tax Convention signed by our two countries on August 20, 1976, we would like to clarify the application of the said Convention to the taxation of remuneration paid by a political subdivision of a Contracting State to an individual in respect of services rendered to that subdivision. Paragraph 1 of Article XIX of the Convention provides that such remuneration shall be taxable only in the State of source.

We have been informed by officials of the provincial government
of 24(1)   of a proposal of the Swiss federal government to tax   
                    19(1)     in our view, the provisions of
Article XIX  exempt   19(1)  remuneration from taxation by
Switzerland.

We would appreciate your views in this matter.

Yours sincerely, Christine Savage A/Director Provincial and International Relations Division

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