Home | Databases | WorldLII | Search | Feedback Canadian Treaty Series

Exchange of Notes recording an Agreement between Canada and Greece Providing for the Reciprocal Exemption from Income Tax of Earnings derived from the Operation of Ships [1929] CATSer 5 (30 September 1929)

E102271 - CTS 1929 No. 12

EXCHANGE OF NOTES RECORDING AN AGREEMENT BETWEEN CANADA AND GREECE PROVIDING FOR THE RECIPROCAL EXEMPTION FROM INCOME TAX OF EARNINGS DERIVED FROM THE OPERATION OF SHIPS

I

The High Commissioner for Canada, London, to the Greek Minister, London

LONDON, 30th September, 1929.

His Excellency Monsieur D. Caclamanos,
Greek Legation,
51, Upper Brook Street, W.1.

Your Excellency,

It being the desire of our respective Governments to effect an arrangement for reciprocal exemption from Income Tax of income arising within their respect­ive countries from the operation therein of ships owned or controlled by and used in the business of persons or corporations resident in the country of the other, I have the honour to inform you that the Government of Canada agrees to the following undertaking:

1. In respect of the Dominion of Canada the Canadian Government under­takes that in accordance with the provisions of the Income War Tax Act the income from the operation of ships owned or operated by persons or corpora­tions resident in Greece shall not be liable to taxation.

2. In respect of Greece the Greek Government undertakes that in accord­ance with the Greek law the income from the operation of ships owned or oper­ated by persons or corporations resident in Canada shall in like manner be exempt from taxation.

3. It is understood that the expression "operation of ships" means the business carried on by an owner of ships and that for the purpose of this defini­tion the expression " owner" includes any charterer.

4. It is agreed that the exemption from income tax, on the income derived from the operation of the aforementioned ships shall be deemed to be effective in respect of the income of fiscal periods ending in the year 1929 and each year thereafter until rescinded by either party giving to the other notice one year in advance of the fiscal periods affected, or until otherwise rescinded by the repeal of the income tax laws of either country.

5. It is further agreed that taxes which have been paid by persons or cor­porations resident in the country of the other and which have been paid more than a year from the date hereof shall not be refunded.

I have the honour to be, etc.,

Peter Larkin,

High Commissioner for Canada in London.

II

The Greek Minister, London, to The High Commissioner for Canada, London

LEGATION DE GREECE, 51, UPPER BROOK STREET, W.1

LONDON, 30th September, 1929.

His Excellency Peter Larkin
High Commissioner for Canada,
The Canadian Building,
Trafalgar Square S.W.1.

Your Excellency,

It being the desire of our respective Governments to effect an arrangement for reciprocal exemption from Income Tax of income arising within their respective countries from the operation therein of ships owned or controlled by and used in the business of persons or corporations resident in the country of the other, I have the honour to inform you that the Government of Greece agrees to the following undertaking:

1. In respect of Greece the Greek Government undertakes that in accord­ance with the Greek law the income from the operation of ships owned or operated by persons or corporations resident in Canada shall not be liable to taxation.

2. In respect of the Dominion of Canada the Canadian Government undertakes that in accordance with the provisions of the Income War Tax Act the income front the operation of ships owned or operated by persons or corporations resident in Greece shall in like manner be exempt from taxation.

3. It is understood that the expression "operation of ships" means the business carried on by an owner of ships and that for the purpose of this definition the expression "owner" includes an charterer.

4. It is agreed that the exemption from income tax on the income derived from the operation of the aforementioned ships shall be deemed to be effective in respect of the income of fiscal periods ending in the year 1929 and each year thereafter until rescinded by either party giving to the other notice of one year in advance of the fiscal periods affected, or until otherwise rescinded by the repeal of the income tax laws of either country.

5. It is further agreed that taxes which have been paid by persons or cor­porations resident in the country of the other and which have been paid more than a year from the date hereof shall not he refunded.

I have the honour to be, etc.,

D. Caclamanos,

Greek Minister in London.