The taxation agreement between the French government and the Government of the United Arab Emirates was signed on July 19, 1989 and was amended in 1993 to include today also a multilateral treaty to prevent base erosion since the entry into force on January 1, 2019 (the “Convention”).
The Tax Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income between the Government of France and the Government of Canada was signed on 2 May 1975 and amended in 1987, 1995 and 2010 (the "Convention"). [1]
The objectives of this Convention are manifold. First, the two countries want to promote their economic relations and cooperation in tax matters. In addition, they wish to eliminate double taxation in respect of certain taxes expressly covered by the Convention.
However, the Convention has provided a safeguard: the set-up or strategies put in place by taxpayers, whether natural or legal persons, must not have the sole purpose of obtaining tax relief provided for by the Convention.
The French and Canadian taxes concerned by the Convention are limited to:
This article will help you better understand the tax impacts of your income between the two countries if you are an individual. If you are a company, we have also written an article to guide you.
Canada is one of the most requested countries in terms of immigration, for several reasons: high-quality education, universal health, employment opportunities, cultural and religious diversity…
As a worker and depending on your current situation, you have different opportunities to immigrate to Canada.[1]
Thus, in this article, we will come back point by point on the different opportunities that are available to you as a worker.[2]
We will first study immigration programs at the federal level, namely Express Entry, the program dedicated to the self-employed and the start-up visa program. These programs will allow you to immigrate to all provinces except Quebec (I).
Next, we will discuss the programs created for young people, namely the Working Holiday Permit and the Young Professionals Permit, which make it easier than other programs to immigrate from anywhere in Canada, including Quebec (II).
Finally, the programs specific to the province of Quebec, namely the Quebec program for permanent workers, temporary workers and business people (III), will be apprehended.
Cryptocurrencies appeared in the digital world around ten years ago and are now experiencing significant growth and democratization.
A virtual means of payment that can be used primarily on the Internet, using cryptography to secure transactions and the creation of units, and escaping any control by regulators and central banks, there are now more than 4,000 cryptocurrencies in circulation.
However, their legal framework is sometimes confusing and difficult to understand. This article will therefore aim to study the legislative framework for cryptocurrencies in France, Canada, and the United Arab Emirates, as well as their tax regime. We will then examine, in a non-exhaustive manner, Initial Coin Offerings, a new fundraising phenomenon based on cryptocurrencies.
What exactly are cryptos?
A cryptocurrency is a virtual means of payment that relies on cryptography to secure transactions and the creation of units, and is outside the control of regulators and central banks. Cryptocurrencies are therefore based on a computer protocol for encrypted and decentralized transactions, called blockchain.
The best known is bitcoin, which is a virtual unit of account stored electronically. However, there are now more than 4000 cryptocurrencies in circulation in the world, the best known outside of bitcoin being for example Ethereum, Ripple or even EOS, XRP, Tether, Cardan, Stellar, Chainlink, Uniswap, Polkado or even USD Coin.
Cryptocurrencies are part of the broader framework of crypoactives, which represent " virtual assets stored on an electronic medium allowing a community of users accepting them as payment to carry out transactions without having to resort to legal currency ".
The issue and circulation of digital cryptoassets is notably linked to Initial Coin Offerings (“ICO”)Unlike an IPO, the ICO is financed on digital media known as tokens (tokens). The ICO thus represents a fundraising operation operating via the issuance of digital assets exchangeable for cryptocurrencies during the start-up phase of a start-up or business project.
The tax convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital between the French government and that of Canada was signed on May 2, 1975 and was amended in 1987, 1995 and 2010 (the " Convention ").
The Convention provides specific provisions for companies and businesses established in Canada but which continue to have links with France.
The taxes covered by the Tax Convention are:
We will return point by point to the different sources of income and their taxation.
Lawyers registered with the Paris and Montreal Bars as well as legal counsel in the Emirates, Conseil Avocate puts its skills at the service of its clients in the fields of business law and tax law with its clients in France, Canada and the United Arab Emirates.
