Treaty detail
Canada - Mexico tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
2006-09-12
Effective
2007-04-12
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 5%
The lower 5 percent corporate rate generally depends on a direct-ownership threshold. Pension funds and certain qualifying recipients may obtain further reductions.
Interest
Rate: 10%
The 10 percent ceiling can be reduced to zero for qualifying government, central-bank, and pension-fund interest under the article.
Royalties
Rate: 10%
Royalties generally face a 10 percent ceiling. Industrial-equipment and certain copyright categories may face different rates under the article.
Permanent establishment
Construction threshold: more than 6 months
Dependent-agent analysis follows the OECD model wording as adapted in the treaty.
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 for dual residents.
Article 4 is the entry point for treaty entitlement and matters particularly for cross-border individuals and for entities whose residence depends on the treaty rather than purely domestic law.
Article 5
Permanent Establishment
Sets the business-presence threshold including service-PE provisions.
The treaty includes both a construction-site threshold and a service-PE rule, with day-counting that requires careful tracking for service-based engagements.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 follows OECD-aligned profit-attribution principles updated by the 2006 treaty.
Article 10
Dividends
Caps source-country withholding on dividends at treaty ceilings.
Article 10 produces the 15 percent portfolio rate and the lower 5 percent direct-investment rate. Pension funds may obtain further reductions under the article.
Article 11
Interest
Limits source-country withholding on qualifying interest with zero treatment for specified categories.
Article 11 produces a 10 percent ceiling but allows zero treatment for qualifying government, central-bank, and pension-fund interest under the article.
Article 12
Royalties
Caps royalties at treaty ceilings that vary with category.
Article 12 generally limits source-country royalty withholding to 10 percent, with category-specific differences for industrial-equipment and copyright royalties.
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–MX treaty
- TreatyGB–CA treaty
- TreatyAU–CA treaty
- TreatyCA–DE treaty
- TreatyCA–FR treaty
- TreatyCA–JP treaty
- TreatyCA–CN treaty
Primary sources
- Canada Department of Finance: tax treaties - MexicoVerified 2026-05-20
- SAT (Mexico) tratadosVerified 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.