If he is a national of either state or one, the matter is resolved by the competent authorities of the contracting states. 3. For the purposes of Article XXII, paragraph 3 (consultation) of the General Agreement on Trade in Services of the Marrakech Agreement establishing the World Trade Organization of 15 April 1994 in Marrakech, States Parties agree that, notwithstanding this paragraph, any dispute between them over whether a measure falls within the scope of that agreement can be submitted to the Council for Trade in Services. , as provided in this paragraph, only with the agreement of the two States Parties. Any doubts about the interpretation of this paragraph are removed in accordance with paragraph 4 of Article 23 or, in the absence of agreement under that procedure, under another procedure agreed by the two States Parties. The Canada-New Zealand agreement replaces the 1980 agreement between the two countries with a more modern one. 1. States parties commit each other to assist each other with regard to the collection of revenue fees. This support is not limited by Articles 1 and 2.
The competent authorities of the States Parties agree on the nature of the application of this article, including the agreement to guarantee a comparable level of assistance. The main feature of the agreement is the reduction of WHT rates for dividends, royalties and interest payments. On June 26, 2015, an updated Double Taxation Agreement (DBA) between Canada and New Zealand came into effect. In general, the new agreement will reduce withholding tax (WHT) on dividends, interest and royalties between the two countries and has been welcomed by investors in both countries. The amendments will take effect on August 1, 2015. 2. The competent authority referred to in paragraph 1 endeavours to resolve the matter by mutual agreement with the competent authority of the other State party where the objection appears justified and is not in a position to find a satisfactory solution to resolve the matter by mutual agreement with the competent authority of the other contracting State, so as not to avoid taxation in accordance with the convention. Any agreement reached will be implemented in the domestic law of the States Parties, regardless of the time frame. On July 2, 2015, New Zealand Finance Minister Todd McClay announced that the New Zealand Double Taxation Agreement (DTA) came into force on June 26, 2015. The new DBA was signed on 3 May 2012 and the accompanying protocol was signed on 12 September 2014. The new DBA replaces the 1980 Treaty. However, these dividends may also be taxed in the contracting state where the resident company is established and, according to state law, but if the beneficiary is the actual beneficiary of the dividends, the amount of tax thus calculated cannot exceed 15% of the gross amount of dividends.
The competent authorities of the contracting states, by mutual agreement, provide for how this restriction is applied.