CRA is examining whether a server used in cryptocurrency mining is a PE

P-208R essentially encapsulates an OECD view that a server in which core functions of a non-resident entity are carried out can constitute a permanent establishment of that entity. CRA stated:

The CRA currently has a couple of ruling requests that involve cryptocurrency mining, and is currently reviewing whether a non-resident miner with servers in Canada would be considered to have a permanent establishment in Canada by virtue of the mining activities that are carried on through those servers.

Although this response was given in a GST/HST context, the same issue would arise regarding the application of income tax conventions.

Neal Armstrong. Summary of 27 February 2020 CBA Roundtable, Q.21 under ETA s. 123(1) – permanent establishment.