Treaty detail
Australia - Canada tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1980-05-21
Effective
1981-10-29
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 5%
The lower 5 percent corporate rate generally depends on direct-ownership thresholds under the 2002 protocol. Australian franking-credit attribution may apply independently of the treaty for Australian-source dividends.
Interest
Rate: 10%
The 10 percent ceiling can be reduced for qualifying government, central-bank, and certain financial-institution interest under the article.
Royalties
Rate: 10%
Royalties generally face a 10 percent ceiling under the treaty across the core categories.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis follows the treaty wording as amended by the 2002 protocol.
Other treaty flags
Pension treatment is article-specific. The treaty includes detailed pension and government-service provisions.
Seeded article summaries
Article 4
Residence
Defines treaty residence and provides tie-breaker tests as amended.
Article 4 has been refined by protocol. Residence analysis interacts with Australia's domestic 'central management and control' test and Canada's mind-and-management approach.
Article 5
Permanent Establishment
Sets the business-presence threshold including construction and offshore-resource rules.
The treaty includes a 12-month construction-site threshold and provides specific rules for offshore-resource activities relevant to both jurisdictions.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 has been refined by protocol to align with OECD-aligned profit-attribution principles.
Article 10
Dividends
Caps source-country dividend withholding at treaty ceilings.
Article 10 produces the 15 percent portfolio rate and the lower 5 percent direct-investment rate after the 2002 protocol. Australian franking-credit attribution rules may apply independently.
Article 11
Interest
Limits source-country withholding on interest at a 10 percent ceiling with carve-outs.
Article 11 produces a 10 percent ceiling but allows zero treatment for qualifying government, central-bank, and certain financial-institution interest.
Article 12
Royalties
Caps royalties at a 10 percent ceiling across major categories.
Article 12 limits source-country royalty withholding to 10 percent. Article-by-article review is still required for category classification.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–CA treaty
- TreatyUS–AU treaty
- TreatyGB–CA treaty
- TreatyGB–AU treaty
- TreatyCA–MX treaty
- TreatyCA–DE treaty
- TreatyCA–FR treaty
- TreatyCA–JP treaty
Primary sources
- ATO: tax treatiesVerified 2026-05-20
- Canada Department of Finance: tax treatiesVerified 2026-05-20
- OECD MLI matching databaseVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.