AGREEMENT BETWEEN CANADA AND THE UNITED REPUBLIC OF TANZANIA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL
The Government of Canada and the Government of the United Republic of Tanzania desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, have agreed as follows:
I. SCOPE OF THE AGREEMENT
This Agreement shall apply to persons who are residents of one or both of the Contracting States.
1. This Agreement shall apply to taxes on income and on capital imposed on behalf of each Contracting State, irrespective of the manner in which they are levied. 2. There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, as well as taxes on capital appreciation. 3. The existing taxes to which the Agreement shall apply are, in particular: (a) in the case of Canada:
the taxes imposed by the Government of Canada under the Income Tax Act, (hereinafter referred to as “Canadian tax”); (b) in the case of Tanzania:
(i) the income tax and any other tax deemed to be tax on income; (ii) the capital gains tax; and
(iii) the excess profits tax;
(hereinafter referred to as “Tanzanian tax”).
4. The Agreement shall apply also to any identical or substantially similar taxes and to taxes on capital which are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any substantial changes which have been made in their respective taxation laws.
1. For the purposes of this Agreement, unless the context otherwise requires: (a) the term “Canada” used in a geographical sense, means the territory of Canada, including: (i) any area beyond the territorial seas of Canada which, in accordance with international law and the laws of Canada, is an area within which Canada may exercise rights with respect to the seabed and subsoil and their natural resources; (ii) the seas and airspace above every area referred to in subparagraph (i) in respect of any activity carried on in connection with the exploration for or the exploitation of the natural resources referred to therein; (b) the term “Tanzania” means the territory of the United Republic of Tanzania, including any area outside the territorial waters of Tanzania which has been or may be designated or proclaimed under the laws of Tanzania as an area over which Tanzania may exercise its sovereign rights of jurisdiction in accordance with international law; (c) the terms “a Contracting State” and “the other Contracting State” mean, as the context requires, Canada or Tanzania; (d) the term “person” includes an individual, an estate, a trust, a company, a partnership and any other body of persons; (e) the term “company” means any body corporate or any entity which is treated as a body corporate for tax purposes; in French, the term “société” also means a “corporation” within the meaning of Canadian law; (f) the terms “enterprise of a Contracting State” and “enterprise of the other Contracting State” mean respectively an enterprise carried on by a resident of a Contracting State and an enterprise carried on by a resident of the other Contracting State; (g) the term “competent authority” means:
(i) in the case of Canada, the Minister of National Revenue or his authorized representative, (ii) in the case of Tanzania, the Minister for the time being responsible for Finance or his authorized representative;...