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In its December 13, 2013 Press Release, Wheaton announced the settlement of its appeal of these reassessments to the Tax Court: Wheaton Precious Metals Corp (“Wheaton” …) … has reached a settlement with the … CRA … which provides for a final resolution of Wheaton’s tax appeal in connection with the reassessment under transfer pricing rules of the 2006 to 2010 taxation years (the “Reassessments”) related to income generated by the Company’s wholly-owned foreign subsidiaries (“Wheaton International”) outside of Canada. ... Interest will be adjusted consequentially …. These transfer pricing principles will also apply to all taxation years after 2010, including the 2011 to 2015 taxation years which are currently under audit and on a go forward basis [as to transfer pricing matters under current law]. ...

… Once an eligible employer has determined that it has experienced the required reduction in revenue for a particular claim period, it is automatically considered to have experienced the required reduction in revenue for the immediately following claim period (deeming rule). As a result, the employer does not have to make this determination again for that next claim period …. … In a situation where the eligible employer, subsequently determines that it actually experienced the required reduction in revenue, without applying the deeming rule, for the second claim period- April 12 to May 9, 2020, the eligible employer will be considered to have experienced the required reduction in revenue for that third claim period because of the deeming rule that can now be applied to the third period …. ...

Underused Housing Tax Notice UHTN13 Exemptions for New Residential Properties February 2023-- summary under Paragraph 6(7)(k) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Underused Housing Tax Act- Section 6- Subsection 6(7)- Paragraph 6(7)(k) Application of GST/HST guidelines on meaning of “substantial completion” What is substantial completion … The … CRA … has guidelines and criteria under the goods and services tax/harmonized sales tax (GST/HST) to determine when construction is substantially completed. ...

P-208R "Meaning of Permanent Establishment in Subsection 123(1) of the Excise Tax Act (the Act)" 23 March 2005-- summary under Permanent Establishment Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Permanent Establishment Meaning of fixed place of business …The fact that space at the disposal of a particular person is at the place of business of another person does not preclude the possibility that that space may be considered to be a place of business of the particular person … [f]or instance … space at the disposal of a non-resident at its client’s premises that is necessary for the non-resident to perform the service that it has agreed to supply to the client in the ordinary course of its business. … Space at the disposal of a person can also exist at the location of equipment or machinery that is at the disposal of the person. … The place of business must be “fixed” in that it must be established at a particular location with a certain degree of continuity and permanency. … [I]t is not necessary that the equipment be affixed to real property to be considered fixed. Rather, the equipment must merely remain at the place of business for a sufficient period of time to be considered fixed. … There must be control at the place of business. … Control can … exist at a place of business where employees are not required to be present in order for important operational decisions to be made, such as … where operational activities … are carried out through automated equipment at the disposal of the business. … The presence of personnel … is not required … if no personnel are required at that location to operate the equipment …. ... There must be a large degree of involvement through the fixed place of business in making or facilitating supplies by the person. … The presence of any of these factors is usually enough to indicate that supplies are being made through a fixed place of business: there is authority at the fixed place of business to enter into contracts or accept purchase orders for the provision of supplies to other persons and that authority is regularly exercised; the tangible personal property that is being supplied is physically manufactured or produced at the fixed place of business; if the supply is a service, the service is performed at the fixed place of business; or, the service of maintaining equipment supplied by the non-resident person, is performed at the fixed place of business (e.g., an authorized factory repair outlet). … A fixed place of business of a particular person that is used solely for the purpose of carrying on activities that are of a preparatory or auxiliary nature in relation to the particular overall business activity of the person does not constitute a fixed place of business of the person through which the person makes supplies. ...

Example 7 – Service supplied in a participating province In a claim period, a non-registrant PSB acquires software programming services from a supplier in Ontario for $35,000. ... The PSB pays $4,550 in HST ($35,000 × 13%). … The PSB is required to self-assess tax at the rate of 2% on the value of the consideration for the supply of the services purchased in Ontario (2% being the difference between the 10% rate of the provincial part of the HST in Prince Edward Island and the 8% rate of the provincial part of the HST in Ontario) to the extent (expressed as a percentage) that the services are used in Prince Edward Island. The PSB self-assesses tax of $140 ($35,000 × 2% × 20%) on Form GST489…....refer to NOTICE 266.... ...