Submitted by Anonymous (not verified) on Sun, 11/29/2015 - 02:15
non-resident call centre not rendering services in Canada
A Canadian company outsourced some of its activities to a non-resident enterprise, so that the non-resident now operates a call centre which...
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Principal Issues: Whether subsection 105(1) of the Regulations applies to a payment made to a non-resident in respect of call centre services performed outside Canada?
Position: Question of fact, but generally no.
Reasons: Telecommunication system appears to be used as a means of transmission
