Words and Phrases - "know-how"

a
82
b
44
c
75
d
50
e
37
f
31
g
17
h
13
i
71
j
2
k
2
l
30
m
51
n
25
o
38
p
79
q
2
r
74
s
85
t
44
u
14
v
8
w
20
y
2
“
1

Hasbro Canada Inc. v. The Queen, 98 DTC 2129, [1999] 1 CTC 2512 (TCC)

Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d)

The taxpayer, which was a Canadian manufacturer and distributer of toys in Canada, paid fixed commissions expressed as a percentage of the...

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Words and Phrases
know-how substantially all

 Transfer Pricing Memorandum TPM-06,  “Bundled Transactions” 16 May 2005

Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 12
distinction between know-how and services provision

After noting the exemption in Art. 12 of the Canada-U.S. Tratyu for payments for the use of or right to use know-how, but not for the provision of...

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Words and Phrases
know-how
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) 147