22 December 1999 External T.I. 9905145 F - ÉTABLISSEMENT STABLE AU CANADA-MALAISIE -- attach -- Article 5
Canadian parent that facilitated sales of its Malay sub could be a dependent agent
Article 5
Hyatt International Southwest Asia Ltd. v. Additional Director of Income-Tax, Civ. App. No. 9766 of 2025 (Supreme Court of India) -- attach -- Article 5
a Hyatt UAE company providing hotel supervisory services had a PE in India
Cour Administrative (2025), Case no. 50602C (Luxembourg High Administrative Court) -- attach -- Article 5
a PE can ambulate within an office complex
Hetal Kotecha, "Canadian Tax Concerns Arising from the Use of Professional Employer Organizations", International Tax Highlights (IFA), Vol. 3, No. 3, August 2024, p. 9 -- attach -- Article 5
Commissioners for His Majesty's Revenue and Customs v GE Financial Investments, [2024] EWCA Civ 797 -- attach -- Article 5
passive holding of intercompany loans was not carrying on business for purposes of PE definition in UK-US Treaty
2024 Ruling 2023-0984281R3 - Remote services and permanent establishment -- attach -- Article 5
ruling that using employees to provide on-line health services to non-resident patients from home offices in Canada does not create a PE in Canada
21 November 2023 Internal T.I. 2021-0880101I7 - Article 5(3)(b) of the Canada-Mexico Treaty -- attach -- Article 5
the “six months” test in Art. 5(3)(b) of the Mexico Treaty should be day-counted (more than 183 days)
23 November 2023 Internal T.I. 2020-0850381I7 - Article V(4) of the Canada-U.S. Treaty -- attach -- Article 5
the 3-month threshold for a drilling rig to be a PE under the Canada-US Treaty is counted based on days of consecutive or non-consecutive use including standby time
27 January 2003 External T.I. 2002-0169385 F - Un serveur et l'établissement stable -- attach -- Article 5
Canadian servers of Swiss company would not be a PE if sales of its product not made through the website
17 May 2023 IFA Roundtable Q. 5, 2023-0965771C6 - Remote Work Arrangements -- attach -- Article 5
whether employee’s home office can constitute a PE of US employer
Pages
