For more details, HMRC is www.gov.uk/government/publications/announcements-in-2014-of-changes-to-uk-double-taxatation-treaties/canada-entry-into-force-of-the-2014-protocols-to-the-1978-double-taxation-convention-as-amended The agreement contains provisions to refuse to provide contract services where it is reasonable to „conclude, taking into account all relevant facts and circumstances, that the granting of this benefit was one of the main purposes of an agreement or transaction that led to that benefit, directly or indirectly, unless it is established that, in these circumstances, the granting of that benefit is consistent with the purpose and purpose of the relevant provisions of the agreement.“ The agreement contains a new preamble that defines the purpose and purpose of the agreement to eliminate double taxation, but not to create opportunities for non-taxation or reduced taxation by tax evasion or evasion (including through contractual shopping agreements to free up facilities for the benefit of a resident of a third jurisdiction). In Articles 10 to 12, specific provisions have been added to exclude contractual benefits for dividends, interest and licence fees when the primary purpose or one of the main purposes of an agreement is to obtain a tax benefit. New provisions will provide greater security for taxpayers, including provisions requiring Canada and the United Kingdom to cooperate in determining a taxpayer`s place of tax residence, including for dual-place businesses. The DBA already contains provisions that allow for adjustments to ensure that the length of the weapons ends with respect to transactions with related parties. There has also been no change in the provisions of the agreement on the stable establishment provision, with some others having previously decided to expand the scope of these provisions after the OECD`s work in this area. 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 unable to find an appropriate solution to resolve the case by mutual agreement with the competent authority of the other contracting State, so as not to avoid taxation in accordance with the convention.