Canada–Serbia Tax Convention Act, 2013 (S.C. 2013, c. 27, s. 3)

At the time of signing of this Convention between the Republic of Serbia and Canada for the Avoidance of Double Taxation with respect to Taxes on Income and Capital (hereinafter referred to as Convention), the undersigned have agreed upon the following provisions, which shall form an integral part of this Convention:

• 1 With reference to paragraph 4 of Article 13 of this Convention, it is understood that the term comparable interests includes an interest in a partnership or trust.

• 2 With reference to subparagraph 2) of paragraph 1 of Article 14 of this Convention, it is understood that in the determination of the income of the individual there shall be allowed as deductions those deductible expenses incurred for the purposes of earning the income as is derived from the activities performed in the other Contracting State.

• 3 It is understood that, should Serbia become a member of World Trade Organization, the following provision would apply:

  For the purposes of paragraph 3 of Article XXII (Consultation) of the General Agreement on Trade in Services, of the Agreement Establishing the World Trade Organization, done at Marrakesh on 15 April 1994, the Contracting States agree that, notwithstanding that paragraph, any dispute between them as to whether a measure falls within the scope of this Convention may be brought before the Council for Trade in Services, as provided by that paragraph, only with the consent of both Contracting States. Any doubt as to the interpretation of this paragraph shall be resolved under paragraph 4 of Article 25 or, failing agreement under that procedure, pursuant to any other procedure accepted by both Contracting States.

IN WITNESS whereof the undersigned, duly authorised thereto, by their respective Governments, have signed this Protocol.

DONE in duplicate at Belgrade, this 27th day of April 2012, in the English, French and Serbian languages, each version being equally authentic.