Canada-Argentina Income Tax Convention Act, 1994

Here is a summary of the provided tax treaty article:

Article 5: Permanent Establishment

• A permanent establishment (PE) exists if an enterprise of one Contracting State has a fixed place in the other Contracting State, which is used for business activities.
• A PE can be considered as existing even if it does not have employees or personnel engaged by the enterprise for such purpose, but only where such activities continue within the country for a period or periods aggregating more than six months within any twelve-month period.

Article 6: Income from Immovable Property

• Income derived from immovable property (including income from agriculture or forestry) situated in one Contracting State and owned by a resident of the other Contracting State may be taxed in that other State.
• The term "immovable property" includes any option or similar right in respect thereof, as well as property accessory to immovable property.

Article 7: Business Profits

• The profits of an enterprise of one Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a PE situated therein.
• If the enterprise carries on or has carried on business as aforesaid, the profits of the enterprise may be taxed in the other State but only so much of them as is attributable to:
  • The PE;
  • Sales in that other State of goods or merchandise of the same or similar kind as those sold through that PE; or
  • Other business activities carried on in that other State of the same or similar kind as those effected through that PE.

Article 8: Shipping and Air Transport

• Profits derived by an enterprise of one Contracting State from the operation of ships or aircraft in international traffic shall be taxable only in that State.
• Notwithstanding the provisions of paragraph 1, profits derived from the operation of ships or aircraft used principally to transport passengers or goods exclusively between places in a Contracting State may be taxed in that State.

Article 9: Associated Enterprises

• Where an enterprise of one Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, and conditions are made or imposed between the two enterprises which differ from those which would be made between independent enterprises, then any income which would have accrued to one of the enterprises but for those conditions may be included in the income of that enterprise and taxed accordingly.

Article 10: Dividends

• Dividends paid by a company which is a resident of one Contracting State to a resident of the other Contracting State may be taxed in that other State.
• However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed 15% of the gross amount of the dividends.