Government of Canada / Gouvernement du Canada
Symbol of the Government of Canada


Canada–Madagascar Tax Convention Act, 2018 (S.C. 2019, c. 7)

Assented to 2019-05-27

SCHEDULE 2(Section 2)Protocol

At the moment of signing the Convention between Canada and the Republic of Madagascar for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, the undersigned have agreed upon the following provisions which shall be an integral part of the Convention:

  • 1 It is understood that, for the purposes of the Convention, the term “head office of the enterprise” signifies, in the case of Canada, the place of incorporation of the enterprise.

  • 2 It is understood that nothing in the Convention shall be construed as preventing Canada from imposing a tax on amounts included in the income of a resident of Canada with respect to a partnership, trust, or controlled foreign affiliate, in which that resident has an interest.

IN WITNESS WHEREOF the undersigned, duly authorized to that effect by their respective Government, have signed this Protocol.

DONE in duplicate at Antananarivo, this 24th day of November 2016, in the English and French languages, each version being equally authentic.


Sandra McCardell


Gervais Rakotoarimanana

Date modified: