Last reviewed 2026-10-20
First edition, partly verified. Every rule here links to the source we opened, and what we could not confirm is listed in the “not verified” section near the end. An independent legal and tax review is still to come: treat this as a research starting point.
Most Canadians who sell to the UK sell services from Canada or ship goods, and few need a UK company on day one. The traps are UK VAT, the off-payroll (IR35) rules, product marking and sending staff to the UK. This guide uses government sources and treaty and statute texts. What could not be opened is listed in section 14. Section 12 is for UK readers who want to work with Canadians.
1. At a glance
Trade figures
| Measure | Figure | Source |
|---|---|---|
| Total UK-Canada trade in goods and services, calendar 2025 | £33.7 billion (UK exports £19.2 billion, UK imports £14.4 billion) | DBT Canada factsheet, released 24 Sept 2026 |
| Same, 12 months to end of Q1 2026 | £35.3 billion; services 48.0% of the total | Same factsheet |
| UK imports from Canada, 12 months to Q1 2026 | £15.6 billion (goods £10.7 billion, services £5.0 billion) | Same factsheet |
| Largest UK service imports from Canada | "Other business services" £2.4 billion (47.4% of UK service imports from Canada); this category includes R&D and management consulting | Same factsheet |
| Canada's merchandise exports to the UK, Aug 2026 | $5,722 million (seasonally adjusted); imports from the UK $899 million | Statistics Canada, The Daily, 2026-10-06 |
Two cautions. The UK's goods imports from Canada include a large "unspecified goods" line of £6.2 billion, and headline trade statistics include non-monetary gold, which swings the totals (DBT's factsheet says so). Statistics Canada's monthly figures also move a lot. Use both as context, not a forecast.
Agreements and status
| Item | Status as of 2026-10-20 | Source |
|---|---|---|
| Canada-UK Trade Continuity Agreement (TCA) | In force since 1 April 2021. Covers goods tariffs, rules of origin, services, investment, IP and procurement. Its investor-state dispute provisions are not in force pending a joint review. | GOV.UK: Trade with Canada, Global Affairs Canada timeline |
| UK in CPTPP, as between Canada and the UK | UK traders can use CPTPP with Canada from 1 September 2026 | GOV.UK: UK and CPTPP |
| Upgraded bilateral free trade agreement | Negotiations launched 24 March 2022 and later broke down. Leaders agreed in June 2025 to restart work. GOV.UK says in September 2026 that the UK "is also negotiating" an upgraded deal. No concluded text found. | GAC timeline, Globe and Mail, 15 June 2025, GOV.UK |
| Tax treaty | Convention signed 8 Sept 1978, in force 17 Dec 1980, amended by protocols in 1980, 1985, 2003 and 2014, plus the MLI | HMRC DT4600 |
| Currency | Pound sterling (£, GBP) | n/a |
| Time zone | GMT, and BST (one hour ahead) from the last Sunday of March; clocks go back on 25 Oct 2026 and forward on 28 Mar 2027 | GOV.UK: clock changes |
How we got here: an AFP report says the UK paused the bilateral talks, with British cheese imports into Canada and Canadian beef exports to the UK as sticking points (AFP via IBTimes UK; the copy opened has no date, and the Globe places the breakdown in 2024). A law-firm article says Canada's implementing Act received royal assent on 6 May 2026 and Canada ratified the UK accession protocol on 3 July 2026 (Gowling WLG, 11 Sept 2026). That article is secondary. The GOV.UK entry date is the primary one.
The TCA does not go away. The same law firm says CPTPP is an additional framework, and that businesses should compare both for each product and use the better one. For Canadian goods going to the UK, the UK importer claims the preference, so tell your buyer which agreement you are using (section 6).
2. Where Canadians win
Services were 48.0% of two-way trade in the 12 months to Q1 2026 (DBT factsheet). Canada supplied 1.7% of UK goods imports in the 12 months to Q1 2026 (same factsheet), so goods sellers should expect a market where specifics matter.
| Lane | Why it fits | What to check |
|---|---|---|
| Consulting, R&D, technical and management services | Largest UK service import from Canada. B2B services are generally VAT reverse-charged (section 4). | Whether the client is "UK-connected" for IR35 (section 3) |
| Software and digital services | The TCA has no dedicated digital trade chapter; CPTPP adds one, per Gowling WLG. | UK VAT on B2C sales (section 4); data transfers (section 5) |
| Energy and resource goods | Crude oil is among the top goods flows in both directions in the DBT data (UK exports £1.9 billion; UK imports £716 million). | Product rules, permits and sector regulators |
| Goods with CPTPP or TCA preference | Preferential tariffs; CPTPP origin cumulation lets inputs from CPTPP members count, per Gowling WLG | Rules of origin by product; UKCA or CE marking |
| Public procurement | The TCA includes procurement; CPTPP widens coverage, per Gowling WLG. NHS healthcare services remain excluded. | Thresholds and the UK procurement portal rules (not verified) |
GOV.UK says the TCA lets UK businesses temporarily move highly skilled professionals to Canada (GOV.UK). The page does not describe the Canada-to-UK direction; see section 8.
3. Services or goods, and which structure
Services from Canada
Selling services from Canada to UK clients needs no UK entity if no UK presence arises. The treaty protects you: under Article 7 as replaced in 2014, the profits of a Canadian enterprise are taxable only in Canada unless it carries on business in the UK through a permanent establishment (PE) (Treaty Series 2014/30).
What creates a PE
| Fact pattern | Treaty rule | Source |
|---|---|---|
| Fixed place of business (office, branch, workshop) | PE if business is wholly or partly carried on there | Art. 5, Convention |
| Building site or construction project | PE only if it lasts more than 12 months | Same |
| Storage, display or delivery of your own goods; purchasing; information gathering; preparatory work | Not a PE on its own | Same |
| Agent who habitually exercises authority to conclude contracts in your name | Deemed PE | Same, Art. 5(4) |
| Independent broker or commission agent acting in ordinary course | Not a PE | Same, Art. 5(5) |
The treaty texts opened contain no separate "services PE" test. The MLI also modifies the treaty and HMRC says a synthesised text exists (DT4600); we did not open it (section 14). A non-UK company trading through a dependent agent PE must register for corporation tax within 3 months of becoming liable (GOV.UK).
Entity options
| Option | What it is | Key facts | Source |
|---|---|---|---|
| Sell cross-border, no entity | Canadian company invoices UK clients | Watch PE, VAT and IR35 | n/a |
| UK establishment of an overseas company | Branch or place of business of the Canadian company | Must file a return with Companies House within one month of opening; form OS IN01, fee £124; directors must verify identity | Overseas Companies Regulations 2009, reg 4, OS IN01, ID verification |
| UK private limited company | Separate UK subsidiary | Separate legal entity; pays UK corporation tax on its profits; files accounts and confirmation statements; registers for VAT if required | GOV.UK: set up a private limited company |
| Dependent agent in the UK | Agent acts for you | May be a PE; register for corporation tax | GOV.UK DAPE |
A tax adviser should price the branch against the subsidiary. See Set up a Canadian subsidiary or branch for the mirror image.
IR35 (off-payroll) for Canadian contractors with UK clients
The rules apply where a worker provides services through their own intermediary (often a personal service company) and would have been an employee if engaged directly (GOV.UK: Understanding off-payroll working).
- If the client is based wholly overseas, with no UK residence and no UK PE, the Chapter 10 rules do not apply and the worker's intermediary must consider the older intermediary rules instead (HMRC ESM10025).
- If the client is UK-resident or has a UK PE, a medium or large non-public-sector client generally decides the worker's status and issues a status determination statement (GOV.UK: for clients).
- If the worker is treated as employed for tax, the "deemed employer" deducts income tax and employee National Insurance from fees and pays employer National Insurance (GOV.UK).
- HMRC says the residence of the intermediary does not matter. What matters is whether the worker would be chargeable to UK tax or National Insurance if engaged directly. A worker doing duties in the UK is normally in scope (ESM10025).
- The passage opened does not spell out the case of a Canadian-resident worker who does all work in Canada for a UK-connected client. Get written advice on that case (section 14).
For small clients, the worker's intermediary decides status (GOV.UK).
4. Tax
Treaty rates on payments from the UK to Canada
| Payment | Treaty rule | Source |
|---|---|---|
| Dividends | Source-country tax capped at 5% if the beneficial owner is a company controlling at least 10% of the voting power; 15% otherwise | SI 2003/2619 |
| Interest | Capped at 10%. Interest between arm's-length parties is not taxable in the source country, except contingent or profit-linked interest. Interest on loans guaranteed or insured by Export Development Canada is taxable only in Canada. | Treaty Series 2014/30 |
| Royalties, general | Capped at 10% | Same |
| Royalties: copyright (literary, dramatic, musical, artistic; not films or TV), patents and know-how (not rental or franchise), computer software | Taxable only in the recipient's country | SI 2003/2619, Art. 12(3) as replaced; wording adjusted by Treaty Series 2014/30 |
| Employment income | Taxable only in the home state if the person is in the other state 183 days or fewer in the calendar year, the employer is not resident there, and the pay is not borne by a PE there | Art. 15 |
| Professional services | Taxable only in the home state unless a fixed base is regularly available in the other state | Art. 14 |
Treaty relief from UK withholding tax on interest and royalties is not automatic. An overseas company applies to HMRC on the DT Company form, with certification of residence, unless a passport scheme covers it (GOV.UK). A UK payer may give relief on royalties without HMRC authorisation if it is UK-based and reasonably believes the payee qualifies (same page).
UK corporation tax
The UK main rate is 25%. A small profits rate of 19% applies to profits of £50,000 or less, with marginal relief between £50,000 and £250,000 (GOV.UK: Corporation Tax rates). A branch or PE is taxed on profits attributable to it under Article 7. A non-UK company that does not register with Companies House but trades through a dependent agent PE registers for corporation tax separately (GOV.UK).
UK VAT
| Situation | Rule | Source |
|---|---|---|
| B2B services from Canada to a UK business | General rule: supplied where the customer belongs, so the UK customer accounts for VAT under the reverse charge. A non-UK supplier that only makes reverse-charge supplies in the UK is not entitled to register. | VAT Notice 741A |
| B2C electronically supplied, telecoms and broadcasting services | Place of supply is where the consumer is, so UK VAT applies to sales to UK consumers | Notice 741A, s. 14 |
| Overseas business supplying the UK | GOV.UK says a business based outside the UK that supplies goods or services to the UK must register regardless of turnover. The UK domestic threshold is £90,000 of taxable turnover. Read this with the row above: a supplier whose only UK supplies are reverse-charged cannot register. | GOV.UK: when to register |
| Goods sold direct to UK customers in consignments of £135 or less | Seller charges and accounts for UK VAT at the point of sale and registers. Low value consignment relief has been removed in Great Britain. | GOV.UK: overseas goods sold directly |
| Same, B2B sale to a customer who gives a UK VAT number | Seller need not charge VAT; customer accounts under the reverse charge. Sellers selling only to UK VAT-registered businesses need not register. | Same |
| Consignments above £135 | Normal import VAT and customs duty apply at the border | Same; Import goods into the UK |
A UK VAT registration brings UK VAT returns and record-keeping. HMRC also publishes a form for appointing a tax representative for non-established taxable persons (VAT1TR); we did not open the representative rules (section 14).
The Canadian side
- Foreign tax credit. A Canadian resident can deduct foreign non-business-income tax up to a limit under Income Tax Act s. 126(1), and business-income tax under s. 126(2), which also carries unused credits across years (the text counts 10 preceding and 3 following years). Keep UK tax receipts.
- GST/HST on exports of goods and services. Tangible goods exported can be zero-rated under Excise Tax Act Schedule VI, Part V, s. 1 (conditions apply). A general service to a non-resident is zero-rated by s. 7, which excludes "an advisory, consulting or professional service". Section 23 zero-rates advisory, professional or consulting services to a non-resident, with exclusions for litigation in Canada for an individual, services on Canadian real or tangible property and agency services. Confirm the UK client is non-resident for GST/HST purposes.
- Quebec. Quebec sellers also deal with the QST; check Revenu Québec for your service (not verified here).
- Currency. Convert UK amounts to Canadian dollars under CRA rules (not opened for this guide; section 14).
See Sell software and digital services across borders and Export goods from Canada.
5. Legal and contracts
Governing law and forum
We did not open a source on how courts treat a choice of English or Canadian law, so treat that as a drafting question for your lawyer (section 14). Decide four things in writing: governing law, forum or arbitration seat, language and currency.
Enforcing judgments between Canada and the UK
The UK and Canada signed a reciprocal judgments convention in 1984. It was ratified on 1 October 1986 and entered into force on 1 January 1987 (SI 1987/468). The UK Order extends Part I of the Foreign Judgments (Reciprocal Enforcement) Act 1933 to judgments in civil or commercial matters given by recognised Canadian courts. Judgments given after 31 December 1986 are enforced in the UK on registration in the High Court, the Court of Session or the High Court of Northern Ireland. The Order's definition of a judgment includes an arbitration award that has become enforceable in the same way as a judgment of a recognised court.
| Canadian courts recognised by UK order | Source |
|---|---|
| Federal Court; courts of British Columbia, Manitoba, New Brunswick, Nova Scotia, Ontario | SI 1987/468, art. 3 |
| Yukon (added from 1 Jan 1988); Prince Edward Island (from 17 Sept 1988); Saskatchewan (from 1 Dec 1988) | SI 1987/2211, SI 1988/1304, SI 1988/1853 |
| Northwest Territories (from 29 June 1989); Newfoundland (from 1 Aug 1991); Alberta (from 13 Aug 1992) | SI 1989/987, SI 1991/1724, SI 1992/1731 |
A title search on legislation.gov.uk showed no amending order for Quebec or Nunavut. We could not confirm the position for those courts, or the reverse route (UK judgments registered in Canadian provinces), which depends on provincial law. Ask a lawyer in the relevant province (section 14).
Data protection
The UK GDPR restricts transfers of personal data out of the UK. Schedule 21 of the Data Protection Act 2018 lists the 2002 European Commission decision on the adequacy of Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) among the decisions treated as adequacy for UK transfers (DPA 2018 Sch. 21 para 5). On that listing, a transfer from the UK to a Canadian recipient that PIPEDA covers appears to have a ready basis. A recipient outside PIPEDA's scope, such as a public body or an organisation covered only by provincial law, may not. The ICO says its adequacy guidance was updated in 2026 for language in the Data (Use and Access) Act (ICO adequacy regulations); its country list did not load for us, so confirm the current list on the ICO site. For the Canadian side see Privacy and data rules for Canada.
Consumer law
If you sell to UK consumers, Part 2 of the Consumer Rights Act 2015 applies to unfair terms and notices; a trader cannot rely on them and enforcers such as the CMA and Trading Standards can act. A template used for both consumers and businesses must still comply (GOV.UK).
6. Customs, rules of origin and product marking
Duty and preference
- A UK importer needs an EORI number starting with GB to import into England, Scotland or Wales, a commodity code, and a customs agent or declaration process (GOV.UK: Import goods into the UK).
- To claim a tariff preference, the importer checks the trade tariff tool, confirms the goods meet the rules of origin each time, and holds proof of origin. Records are kept at least 4 years (GOV.UK: Pay less customs duty).
- For UK exports to Canada, GOV.UK says a TCA claim rests on an origin declaration by the exporter on an invoice or similar document, and that the product-specific rules use the 2012 Harmonised System (GOV.UK, TCA page). That page is written for UK exporters. Ask a broker what proof the UK importer needs for Canadian-origin goods.
- Since 1 September 2026, CPTPP is also available between Canada and the UK (GOV.UK). A law-firm article says CPTPP allows cumulation of inputs from all members and phases in tariff cuts by product (Gowling WLG). Compare the two for each product.
- Exports leaving Canada have their own reporting; see Export goods from Canada. Hire a licensed customs broker on both sides.
UKCA, CE and conformity
Great Britain recognises CE marking alongside or in place of UKCA for many products under the Product Safety and Metrology (Amendment) Regulations 2024 (GOV.UK: Placing UKCA or CE marked products on the market in GB). Most responsibilities sit with the manufacturer: correct marking, technical documentation, a declaration of conformity and cooperation with market surveillance. If you use an authorised representative, GOV.UK describes it as an individual or company established in the UK, appointed by the manufacturer. The TCA includes mutual acceptance of conformity assessment results for several sectors, such as EMC, ATEX, radio equipment, machinery, toys and electrical equipment (GOV.UK). Check whether your product sector is covered and which conformity bodies apply. Canadian marks such as CSA are not discussed on the pages opened.
Northern Ireland and the Windsor Framework
The pages cited cover Great Britain and treat Northern Ireland separately. If you ship to Northern Ireland, check the NI route first; the Windsor Framework was not reviewed (section 14).
7. Getting paid
- Invoice currency. Invoice in GBP or CAD and fix in the contract who bears exchange-rate risk. Get quotes from several banks or payment firms.
- Late payment. UK statute allows interest on late B2B payments at 8% plus the Bank of England base rate, plus a fixed recovery sum of £40, £70 or £100 depending on the debt (GOV.UK: Late commercial payments). The page says agreed payment dates should usually be within 60 days for business transactions. Whether it reaches a Canadian supplier under a non-UK-law contract was not checked.
- Payment rails. UK domestic schemes (Faster Payments, Bacs) serve UK bank accounts. We did not open scheme documentation, so confirm with your bank how a Canadian company receives GBP (section 14).
- VAT on invoices. Show UK VAT or the reverse-charge note correctly. For B2B goods sold to a UK business, HMRC suggests an invoice note such as "reverse charge: customer to account for VAT to HMRC" (GOV.UK). Verify the customer's VAT number with HMRC's online service.
- Credit risk. Check the buyer on Companies House. Consider credit insurance; see Insurance, credit and payment risk and Get paid from abroad.
8. People and visas
| Route | Key facts | Source |
|---|---|---|
| UK ETA (electronic travel authorisation) | Canadians usually need an ETA, not a visa, for up to 6 months for tourism, family visits, a business trip or short study. Cost £20. | GOV.UK: ETA |
| Business visitor (Standard Visitor) | May attend meetings, conferences and interviews, negotiate and sign deals, attend trade fairs to promote the business (no sales), carry out site visits, and oversee delivery of services supplied by a UK company to your company. Not allowed: paid or unpaid work for a UK company or as self-employed in the UK, except a permitted paid engagement. Up to 6 months. | GOV.UK: Visit on business |
| Youth Mobility Scheme | Canadians aged 18 to 35. Up to 24 months, extendable by one year for Canadians. Fee £340; need £2,530 in savings; healthcare surcharge usually £776 per year. Work in most jobs or self-employment (rented premises, equipment under £5,000, no employees). | GOV.UK: Youth Mobility, eligibility |
| Skilled Worker | Needs an approved sponsor, a certificate of sponsorship and an eligible job. Minimum salary is the higher of £41,700 or the occupation's going rate, with lower-salary exceptions. Fees from £819 (up to 3 years) or £1,618 (over 3 years) from outside the UK; healthcare surcharge usually £1,035 per year. | GOV.UK: your job, costs |
| Global Talent | For leaders or potential leaders in academia or research, arts and culture, or digital technology. Needs an endorsement unless an eligible prize applies. Up to 5 years at a time. | GOV.UK: Global Talent |
| Global Business Mobility | UK Expansion Worker: senior manager or specialist setting up a UK branch for an overseas business that has not yet traded in the UK; up to 12 months, extendable to 2 years. Senior or Specialist Worker: minimum £52,500. Service Supplier: for a contract covered by an international trade agreement, with at least 12 months' employment or experience. | Expansion, Senior or Specialist, Service Supplier |
Check fees and salaries on the day; they change often. A law-firm summary says CPTPP lets business visitors stay up to 90 days in any 12 months and highly skilled professionals on short-term contracts stay up to 12 months, double the TCA's six (Gowling WLG). We found no UK government page for these terms; check the treaty text or UKVI guidance before relying on them.
For work done by UK staff in Canada, see Bring a worker to Canada. To send staff to the UK, use a qualified immigration adviser.
9. Business practice
- Check who you are dealing with. UK companies appear on the Companies House register, with directors and filings (GOV.UK).
- Holidays differ by nation. England and Wales, Scotland and Northern Ireland have different bank holidays. Examples: 30 Nov 2026 in Scotland; 17 Mar 2027 in Northern Ireland (GOV.UK: Bank holidays).
- Time difference. The UK is several hours ahead of the Canadian time zones. UK clocks change on 25 Oct 2026 and 28 Mar 2027 (GOV.UK). Check your province's dates, because the gap can change for a few weeks.
- Contract and invoice details. Put legal names, addresses and tax numbers on contracts and invoices so VAT and reverse-charge treatment is clear.
- Chambers. The Canada-UK Chamber of Commerce (founded 1921, Canada House, London) and the British Canadian Chamber of Trade and Commerce (founded 1951) run events and networks (Canada-UK Chamber, BCCTC).
10. Funding and support
| Source | What it offers | Link |
|---|---|---|
| Trade Commissioner Service, London | Trade and investment services for Canadian businesses in England, Scotland, Wales, Northern Ireland, the Channel Islands and Gibraltar | Canada and the UK |
| Export Development Canada (EDC) | Insurance, guarantees, loans and equity for exporters; its site lists a Trade Impact Program for tariff support | EDC |
| Chambers | Events, networks, member directories | See section 9 |
| CanExport and BDC | Not verified for this guide | See Export funding and financing map |
Related guides: Find buyers, trade shows and trade missions, Sell to governments and large buyers abroad and Diversify beyond the US.
11. Risks
| Risk | Why it matters | Mitigation |
|---|---|---|
| Permanent establishment | UK staff, an office or an agent who signs for you can create a UK tax presence | Take advice before hiring or stationing anyone in the UK |
| IR35 | A UK-connected client may treat you as a disguised employee | Check the client's UK connection; keep evidence of independence |
| UK VAT | Overseas suppliers face registration rules regardless of turnover | Map each product line to the section 4 table |
| Product marking | Unmarked regulated goods cannot be sold in Great Britain | Confirm the UKCA or CE route |
| Trade-deal change | The upgraded bilateral deal is unresolved | Re-check preferences on each shipment |
| Currency | GBP/CAD moves can erase margin | Price in CAD or hedge |
| Enforcement | Judgment recognition depends on the court | Choose forum with advice; consider arbitration |
| Visa breach | Visitors cannot work for a UK company, except permitted paid engagements | Stay within the section 8 activities |
12. If you are in the UK and want to work with Canadians
- Find Canadian suppliers or staff. Start with the chambers (section 9), the British High Commission in Ottawa and DBT's "Trade with Canada" page. See Working with Canadian companies.
- Buying services from a Canadian provider. The B2B reverse charge normally applies; you account for UK VAT on your return (Notice 741A). If a Canadian supplier sends a UK VAT invoice, you must still apply the reverse charge (same page).
- Paying royalties, interest or fees to Canada. HMRC relief under the treaty is not automatic; see section 4. On the Canadian side, a non-resident pays 25% on certain Canadian-source payments such as management fees and royalties, subject to the treaty (Income Tax Act s. 212). That applies if a Canadian company pays you. Confirm the treaty rate with a Canadian CPA.
- Hiring Canadians. See Hire a Canadian employee from abroad and Hire a Canadian freelancer or contractor. If you are a UK-connected client engaging a contractor through a company, IR35 may apply to you (section 3).
- Selling or setting up in Canada. See Import goods into Canada, GST/HST for foreign businesses, Set up a Canadian subsidiary or branch and Doing business in Quebec. Canada's CPTPP procurement schedule covers 22 service categories that the TCA does not, per Gowling WLG.
- UK support. UK Export Finance lists working capital, non-payment insurance and buyer finance. The UK IPO has a North America attaché who supports UK businesses trading with Canada.
13. Checklist and questions
- Decide whether you sell services, goods or both, and to businesses or consumers.
- Check which agreement applies to your goods: the TCA, CPTPP, or neither.
- Confirm whether your UK client is "UK-connected" for IR35 and get written advice if you work through a company.
- Decide whether you need a UK entity, a branch or none; review PE risk.
- Map each sale to the UK VAT table (B2B reverse charge, B2C digital, goods).
- Register for UK VAT if you are an overseas business making taxable UK supplies.
- Confirm treaty relief claims (DT Company form) and keep Canadian foreign tax credit records.
- Check GST/HST zero-rating for each service or good you export.
- Choose governing law, forum and currency; add late-payment and data-protection terms.
- Confirm UKCA or CE route and a UK authorised representative where needed.
- Book visits within the permitted business-visitor activities; apply for a UK ETA early.
- Contact the Trade Commissioner Service in London and EDC before a first deal.
What to ask a lawyer
- Which law and forum suit this contract, and can I enforce a judgment from that court in the other country?
- Do UK GDPR and PIPEDA both apply, and what transfer wording do I need?
What to ask an accountant or tax adviser
- Does my activity create a UK PE under the treaty as amended by the MLI?
- Should I register for UK VAT, and is my client UK-connected for IR35?
- How do I claim the Canadian foreign tax credit and UK treaty relief?
What to ask a customs broker
- What is the commodity code, and does the TCA or CPTPP give a lower rate?
- What proof of origin does the UK importer need, and does my product need UKCA, CE or a UK authorised representative?
14. What this guide did not verify
- Choice of law and enforcement. How courts treat a choice of English or Canadian law; the Canadian-side route to enforce UK judgments; the position for Quebec and Nunavut courts; the Hague conventions.
- Tax treaty. The MLI synthesised text (any change to PE or anti-abuse rules) and the UK domestic withholding rates on royalties and interest.
- IR35. The case of a Canadian-resident worker doing all work in Canada for a UK-connected client.
- UK VAT. Tax-representative rules and whether a Canadian B2C digital seller must register from the first sale (inferred from the overseas-business rule).
- CPTPP. Tariff staging, the 90-day business-visitor stay and procurement terms come from a law-firm summary. Canada's ratification announcement was not opened.
- Customs and marking. Tariff rates by good, Canada-side origin documents, broker licensing, the Windsor Framework, and whether CSA or UL marks are accepted in the UK.
- Data. The live ICO adequacy list did not load; we used the Data Protection Act 2018 transitional list.
- Payments. Faster Payments and Bacs documentation, FX costs and bank options for Canadian companies.
- Canadian tax and funding. CRA currency-conversion guidance, Quebec QST export rules, Regulation 105 withholding, CanExport, BDC, provincial programs and the Canada-UK social security agreement.
- Statistics. UK-reported and Canadian-reported trade figures differ in timing and method.
15. Sources opened
- DBT: Canada trade and investment factsheet (released 24 Sept 2026)
- GOV.UK: Trade with Canada (TCA summary)
- GOV.UK: UK trade agreements in effect
- GOV.UK: UK and CPTPP
- Gowling WLG: CPTPP enters into force between Canada and the UK
- Global Affairs Canada: Canada-UK FTA negotiations timeline
- Globe and Mail: Canada, U.K. commit to trade talks (15 June 2025)
- IBTimes UK (AFP): UK, Canada pause trade talks
- Statistics Canada, The Daily, 2026-10-06, Table 1
- HMRC DT4600: Canada agreements in force
- Double Taxation Relief (Taxes on Income) (Canada) Order 1980, Schedule
- SI 2003/2619 (2003 protocol)
- Canada Treaty Series 2014/30 (2014 protocol)
- GOV.UK: Corporation Tax rates
- GOV.UK: Corporation Tax for non-UK incorporated companies
- GOV.UK: Register through a dependent agent PE
- GOV.UK: Double Taxation Relief for companies
- Overseas Companies Regulations 2009, reg 4
- Companies House: OS IN01
- Companies House: identity verification
- GOV.UK: Set up a private limited company
- GOV.UK: Understanding off-payroll working (IR35)
- GOV.UK: Off-payroll working for clients
- HMRC Employment Status Manual ESM10025
- GOV.UK: When to register for VAT
- VAT Notice 741A: place of supply of services
- GOV.UK: VAT and overseas goods sold directly to customers in the UK
- GOV.UK: Import goods into the UK
- GOV.UK: Pay less Customs Duty (preference agreements)
- GOV.UK: Placing UKCA or CE marked products on the market in GB
- SI 1987/468 and amending orders (judgments)
- Data Protection Act 2018, Sch. 21 para 5
- ICO: adequacy regulations
- GOV.UK: Writing a fair contract for customers
- GOV.UK: Late commercial payments
- GOV.UK: ETA, Standard Visitor: visit on business, Youth Mobility, Skilled Worker, Global Talent, UK Expansion Worker, Senior or Specialist Worker, Service Supplier
- GOV.UK: Clock changes, Bank holidays
- Excise Tax Act (full text), Schedule VI Part V
- Income Tax Act s. 126 and s. 212
- Government of Canada: Canada and the United Kingdom
- EDC: About us
- Canada-UK Chamber of Commerce, BCCTC
- British High Commission Ottawa, UK Export Finance, IPO attaché in North America
Research, not advice. Rules change and depend on your facts: confirm with a qualified Canadian professional before you act. Items we could not verify are labelled in the text.