Do all of Canada's tax treaties work the same way?
No, and assuming they do is where much of the trouble starts. Each agreement has its own residence article, its own withholding rates and its own carve-outs. The same pension, the same royalty and the same capital gain can be taxed in three different places under three of Canada's agreements. There is no general Canadian treaty position you can carry from one country to another. The only reliable method is to read the specific agreement, in the version in force for the year in question, against the facts you actually have.
The UAE has no income tax — what use is a credit article?
Very little, and that is worth understanding early. A credit article relieves double tax by allowing one country to credit tax paid in the other. Where one jurisdiction does not charge income tax on the item, there is nothing to credit, so the relief that carries the weight in other treaties does nothing here. The question becomes residence instead: which country is entitled to tax you at all, and whether you have ceased to be resident in the other. That is a factual question, and it needs evidence rather than an article.
I lived in two countries last year — which treaty applies?
Possibly both, for different parts of the year and different items of income. A treaty applies between two states, so a year with three countries in it can involve more than one agreement, each with its own residence article reaching its own conclusion. The sequence is to settle residence for each period first, then take each item of income and find the agreement and article that covers it. Doing it item by item is slower than looking for one answer, but a single answer for the whole year is usually wrong somewhere.
Is my UK pension taxed in Canada or the UK?
It depends on the pension article of that specific agreement and on what the payment actually is, not on a general rule about pensions. Different retirement payments are treated differently even within one treaty, and the treatment under one of Canada's agreements tells you nothing about another. Characterise the payment first — what fund, what source, what kind of entitlement — then read the article covering that character in the version in force for your year. Where both countries still reach it, relief comes through the credit article rather than exemption.
How do I know which version of a treaty applies?
By checking what was in force for the year you are filing, including any protocol that amended it. Agreements are amended, and an article quoted from an older text can give an answer that was right once. This matters particularly for withholding rates and for carve-outs, which are the provisions protocols tend to touch. When a position is taken, record which version was read and the date it was read, and keep that note with the working papers. It costs a line, and it saves reopening the whole analysis later.
Does moving to Australia change how my Canadian royalties are taxed?
It can change the rate, the country that taxes and the paperwork, because you move from one agreement to another with its own withholding rates and carve-outs. Nothing carries over from your previous country's treaty. Before the move, identify each stream of income you will continue to receive, then check the new agreement article by article to see what applies to each. Withholding is the part that bites first, because the payer applies whatever it has documentation for. Tell the payer about the change and give it the new residence evidence.
How do I claim a tax treaty benefit?
Three things usually have to line up: proof you are resident of the treaty country, a declaration to whoever is paying you so they withhold at the treaty rate rather than the statutory one, and the claim itself on the return of the country giving relief. Do it before the payment where a reduced rate is available — claimed afterwards it becomes a refund exercise instead, which takes far longer. See certificates of residency.
What is a totalization agreement and how do I use one?
A social security agreement that stops you contributing to two systems for the same work, and lets periods in both count towards benefit eligibility in either. Which system you stay in depends on the agreement's rules for your situation — a seconded employee usually remains in the home system for a set period, a locally hired one usually joins the host system. You evidence it with a certificate of coverage obtained before or shortly after the assignment starts. See certificates of coverage.
