Foreign Income from sale of cryptocurrency - which DTA article?

Hello. I am looking for help with how a person who is dual-resident (in the UK and Canada) would declare income from the sale of Cryptocurrency assets on their UK self-assessment tax return. The income is treated as a trade due to the frequency and nature of the transactions. The disposals are chargeable to income tax in Canada, NOT capital gains tax. Can you please advise which article of the UK-CANADA Double Taxation Agreement (DTA) this income would fall under? Thank you.

Hi taxqueries2024,
The UK / Canada tax treaty can be found at:
Canada: tax treaties.
Article 20A(3) covers 'Other Income' not covered elsewhere on the treaty, may be taxed in the UK and Candada.
You may then need to consider article 21, the elimination of double taxation.
Thank you. 

 

Would it not come under Business Profits? Could you kindly please explain why would it be classed as Other Income? Thank you.

Hi taxqueries2024,
If you meet the conditions here:
CRYPTO20250 - Cryptoassets for individuals: what is trading
Then it would be business profits.
Thank you.