CRA applies Dudney to an Irish resident contractor
23 October 2013 - 9:13am
CRA, following Dudney, accepted that an Irish resident who worked as an independent contractor, under a short-term contract, for a provincial authority at its facilities did not have a fixed base or permanent establishment in Canada.
Neal Armstrong. Summary of 18 June 2013 Memorandum 2011-0393451I7 under Treaties – Art. 14.