Canada–Madagascar Tax Convention Act, 2018 (S.C. 2019, c. 7)

At the moment of signing the Convention between Canada and the Republic of Madagascar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, the undersigned have agreed upon the following provisions which shall be an integral part of the Convention:

• 1 It is understood that, for the purposes of the Convention, the term “head office of the enterprise” signifies, in the case of Canada, the place of incorporation of the enterprise.

• 2 It is understood that nothing in the Convention shall be construed as preventing Canada from imposing a tax on amounts included in the income of a resident of Canada with respect to a partnership, trust, or controlled foreign affiliate, in which that resident has an interest.

IN WITNESS WHEREOF the undersigned, duly authorized to that effect by their respective Government, have signed this Protocol.

DONE in duplicate at Antananarivo, this 24^th day of November 2016, in the English and French languages, each version being equally authentic.

FOR CANADA

FOR THE REPUBLIC OF MADAGASCAR