CRA confirms that incidental business activities in Canada generally do not constitute carrying on business in Canada

In Folio S5-F2-C1, CRA provides general guidelines for determining in which countries a business of a Canadian taxpayer is carried on for foreign tax credit purposes.

In the course of a general response, CRA has referenced the same guidelines as applying for purposes of determining whether a non-resident company is carrying on business in Canada. Accordingly, a non-resident company may be able to rely on a helpful statement in S5-F2-C1 that "if…one activity of a business is clearly incidental to a predominant one, the incidental activity is not considered when determining in which country or countries the business is carried on."

Neal Armstrong. Summary of 19 June 2015 T.I. 2013-0475751E5 under s. 115(1)(a)(ii).