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.-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions International rules of interpretation (pp. 24-25) [W]hen interpreting treaties, Canadian courts generally use international rules of interpretation instead of domestic rules. The Supreme Court of Canada has endorsed the principles of treaty interpretation enunciated in sections 31-33 of the Vienna Convention on the Law of Treaties. ...

Krauze, "Impact of Cloud Computing on Permanent Establishments Under the OECD Model Tax Convention", Tax Management International Journal, Vol. 44, No. 3, March 13, 2015, p. 131.-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Categories of Cloud-based services (p.132) The models for providing cloud-based services have traditionally been divided into three categories: Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (laaS). ...

Krauze, "Impact of Cloud Computing on Permanent Establishments Under the OECD Model Tax Convention", Tax Management International Journal, Vol. 44, No. 3, March 13, 2015, p. 131.-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 Categories of Cloud-based services (p.132) The models for providing cloud-based services have traditionally been divided into three categories: Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (laaS). ...

Novek, "Convention Expenses Are Subject to Territorial Limitations", Taxation of Executive Compensation and Retirement, February 1992, p. 557.-- summary under Subsection 20(10) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(10) ...

Commissionnaires: A Comparison In Light of the OECD Model Convention", Tax Notes International, October 7, 2013, p. 59-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 What is a commissionaire arrangement? ...

Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607-- summary under Article 19 Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 19 Only cases where taxes have been charged are covered (p. 611) Under the wording of article 19(l)(a) of the MLI, only cases where taxes have actually been charged can be submitted to arbitration…. ...

Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607-- summary under Article 20 Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 20 Nature of specific case mutual agreement procedure under OECD Model (p. 609) Once the taxpayer has filed an application for a specific case MAP under article 25(1) of the OECD Model … [t]he procedure…consists of two stages. ...

Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607-- summary under Article 28(2) Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 28- Article 28(2) Arbitration reservations are subject to other CTA party’s acceptance (p. 611) Article 28(2)(a) permits the parties to the MLI to formulate one or more reservations with regard to the scope of cases that should be eligible for arbitration under Part VI. ...

Sheppard, "The Brave New World of the Dependent Agent PE", Tax Notes International, Vol. 71, No. 1, 1 July 2013, p. 10-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 A June 14, 2013 conference sponsored by the Vienna University of Economics and Business discussed the dependent agent permanent establishment concept in Article 5(5) of the OECD Model treaty, which provides: Notwithstanding the provisions of paragraphs 1 and 2, where a person — other than an agent of an independent status to whom paragraph 6 applies — is acting on behalf of an enterprise and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall be deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph. ... Independent agent article of OECD Model Convention (pp. 15-16) Article 5(6) states: An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. ...

.-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Retirement compensation arrangement as pension (p. 493) [U]nder the model convention, payments from an RCA are likely to be considered a pension rather than income from employment. From a Canadian perspective, pursuant to the Income Tax Conventions Interpretation Act (ITCIA), RCAs are considered to be pension vehicles if "pension is not otherwise defined in the tax convention concluded between Canada and a foreign country. Advantage if OECD Model followed (p. 493) Article 18 of the model convention provides that pension benefits are taxable only in the state of residence of the beneficiary. ...