Income Tax Conventions Interpretation Act

Article VI of the Canada-Ireland Convention, which provided that "the rate of Canadian tax on income ... derived from sources within Canada by a resident of Ireland shall not exceed 15 percent" applied to limit the rate of capital gains tax payable by a resident of Ireland on the disposition of shares of a Canadian private corporation to 15 percent of the taxable capital gain rather than of the capital gain, given that both Article II(3) of the Convention and s. 3 of the ITCIA mandated that the meaning to be given to a term found in a treaty should be the meaning given to the term from time to time under the Act, unless the context otherwise required.