Income Tax Conventions Interpretation Act (R.S.C., 1985, c. I-4)

Meaning of interest

6 Notwithstanding section 3, the meaning of the term interest in any convention given the force of law in Canada before November 19, 1974 does not include any amount paid or credited, pursuant to an agreement in writing entered into before June 23, 1983, as consideration for a guarantee referred to in paragraph 214(15)(a) of the Income Tax Act.

Marginal note:Transitional

6.1 Where a taxation year of a taxpayer includes June 23, 1983, the additional tax payable under the Income Tax Act (except Part XIII thereof) by the taxpayer for the taxation year by virtue of this Act shall be calculated in accordance with the following formula:

Marginal note:Partnerships

6.2 Notwithstanding the provisions of a convention between Canada and another state or the Act giving it the force of law in Canada, it is hereby declared that the law of Canada is that, for the purposes of the application of the convention and the Income Tax Act to a person who is a resident of Canada, a partnership of which that person is a member is neither a resident nor an enterprise of that other state.

Marginal note:Gains arising in Canada

6.3 Except where a convention expressly otherwise provides, any amount of income, gain or loss in respect of the disposition of a property that is taxable Canadian property within the meaning assigned by the Income Tax Act is deemed to arise in Canada.

Application

Marginal note:Application

7 This Act applies

• (a) in the case of tax under Part XIII of the Income Tax Act, to amounts paid or credited after June 23, 1983; and

• (b) in all other cases, to taxation years ending after June 23, 1983.