Canada Hong Kong Double Taxation Agreement

For example, Canada`s foreign subsidiary rules provide that income from the active activities of the foreign subsidiary of a Canadian corporation that is considered a tax-exempt surplus may be distributed to the Canadian corporation as a dividend without Canadian taxes if the foreign subsidiary is located in a country with which Canada has a tax treaty or tax information exchange agreement (TIEA). Act 5907(11) of Canada`s Tax Act is drafted in such a way that a designated contracting country with which Canada has entered into a comprehensive agreement or agreement to eliminate double taxation includes “a sovereign state or other jurisdiction.” .