Records / Laws and rulings

US-Canada income tax convention, Article XII as amended: 10 percent, and 0 for copyright, software and know-how (Convention between the United States and Canada (1980) as amended, Art. XII(1)-(3) with the Protocol of 17 March 1995, Art. 7)

The general Canadian rate is 10 percent, but copyright royalties, software and information about commercial or scientific experience are taxable only in Canada. A Canadian holder therefore pays 0 percent on a data licence.

Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text

In the source's own words
“Royalties arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State. 2. However, such royalties may also be taxed in the Contracting State in which they arise, and according to the laws of that State; but if a resident of the other Contracting State is the beneficial owner of such royalties, the tax so charged shall not exceed 10 per cent of the gross amount of the royalties. ... (b) Payments for the use of, or the right to use, computer software; (c) Payments for the use of, or the right to use, any patent or any information concerning industrial, commercial or scientific experience (but not including any such information provided in connection with a rental or franchise agreement); ... arising in a Contracting State and beneficially owned by a resident of the other Contracting State shall be taxable only in that other State.”
Figures it counts in

It is shown on its own, not counted into a figure.

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