Memorandum of Understanding between the Competent Authorities of Canada and Switzerland

As provided under clause 3(b)(v) of Article 10 of the Convention between Canada and Switzerland for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital (the "Convention"), the competent authorities have agreed that the following pension and retirement plans generally correspond to a pension or retirement plan recognized for tax purposes in their state:

1. In the case of Canada:
   1. Registered retirement savings plans under section 146 of the Income Tax Act;
   2. Registered retirement income funds under section 146.3 of the Income Tax Act;
   3. Deferred profit sharing plans under section 147 of the Income Tax Act;
   4. Registered pension plans under section 147.1 of the Income Tax Act;
   5. Pooled registered pension plans under section 147.5 of the Income Tax Act;
   6. Plans under the Canada Pension Plan and Old Age Security Act; and
   7. Plans under the Quebec Pension Plan Act.
2. In the case of Switzerland, any pension and retirement plans covered by:
   1. the Federal Act on old age and survivors’ insurance, of 20 December 1946;
   2. the Federal Act on disabled persons’ insurance of 19 June 1959;
   3. the Federal Act on supplementary pensions in respect of old age, survivors’ and disabled persons’ insurance of 6 October 2006;
   4. the Federal Act on old age, survivors’ and disabled persons’ insurance payable in respect of employment or self-employment of 25 June 1982, including the non-registered pension schemes which offer occupational pension plans and the forms of individual recognized pension schemes comparable with the occupational pension plans.