Treaty detail
Canada - China tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1986-05-12
Effective
1986-12-29
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 10% · Corporate rate: 10%
The treaty applies a uniform 10 percent ceiling on dividends. China's domestic dividend-withholding rules continue to apply where treaty conditions are not satisfied.
Interest
Rate: 10%
The treaty applies a 10 percent ceiling on most interest. Certain government, central-bank, and qualifying-institution interest may obtain better treatment under the article.
Royalties
Rate: 10%
Royalties generally face a 10 percent ceiling under the older 1986 treaty, with possible different treatment for industrial-equipment categories.
Permanent establishment
Construction threshold: more than 6 months
Dependent-agent analysis under the older 1986 treaty wording includes specified habitual-conclusion rules.
Other treaty flags
Pension treatment is article-specific under the older 1986 treaty.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the 1986 wording.
Article 4 reflects the older 1986 wording. Residence analysis interacts with China's developing rules on Place-of-Effective-Management.
Article 5
Permanent Establishment
Sets the business-presence threshold including service-PE provisions.
The treaty includes a 6-month construction-site threshold and a service-PE rule. Day-counting is important under the article.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 is the operating rule for cross-border services. The interplay with the service-PE rule means careful day-counting is required.
Article 10
Dividends
Caps source-country dividend withholding at a uniform 10 percent ceiling.
Article 10 does not differentiate dividend rates by direct-ownership level in the way newer treaties do. The 10 percent ceiling reflects the older 1986 wording.
Article 11
Interest
Limits source-country withholding on qualifying interest to a 10 percent ceiling.
Article 11 reflects the older 1986 ceiling on interest, with carve-outs for government and central-bank interest under the article.
Article 12
Royalties
Caps royalties at a 10 percent ceiling under the older treaty.
Article 12 limits royalties at 10 percent generally. Category classification matters for industrial-equipment royalties under Chinese domestic rules.
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–CN treaty
- TreatyGB–CA treaty
- TreatyGB–CN treaty
- TreatyCA–MX treaty
- TreatyAU–CA treaty
- TreatyCA–DE treaty
- TreatyCA–FR treaty
Primary sources
- Canada Department of Finance: tax treatiesVerified 2026-05-20
- State Taxation Administration of ChinaVerified 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.