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Convention are both applicable, the payer is required to withhold 10% on the first $5,000 and 15% on the balance. ...

Income Tax Technical News No. 22, 11 January 2002-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 After referring to Dudney, CRA stated: "We do not propose to litigate another case based on the taxpayer's use of space within the premises of another person unless we can reasonably maintain, based on the particular facts, that the taxpayer in fact had sufficient physical control of the space to carry on those aspects of his or her business that are appropriate to the space. ...

Round Table, Q. 2-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) "In a situation where a non-resident of Canada carries out a series of transactions whose purpose is to secure an exemption from or reduction of Canadian tax through a tax convention that Canada has concluded with another country, the Department will examine this type of situation closely in order to establish whether it results in an abuse. ...

5 May 2021 IFA Roundtable, Q.6-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 disclosure of number and nature of cases brought to arbitration is prohibited When asked to disclose statistics on the number of cases that have been brought to arbitration under each of Canada’s tax treaties and to describe the underlying issues, CRA indicated: Pursuant to international agreements, disclosure of such information is not permitted. ...

The Department is of the view that such a corporation would not be a resident of Barbados for purposes of the tax convention because it is not liable for tax on its world income. ...

1996 Ontario Tax Conference Round Table, Q. 1 (No. 9630030, see also 9621950a)-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 In general, payments to a U.S. or Netherlands resident for rights in respect of the use of custom computer software in Canada will be exempt on the basis of being: payments for the use of, or the right to use, computer software exempt under Article XII; payments in respect of the production or reproduction of software exempt under s. 212(1)(d)(vi); or payments for marketing or distribution rights that are exempt under the business profits article. ...

Income Tax Technical News No. 33, 16 September 16 2005-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 PE factors including legal control of site There are numerous factors to be considered in making a determination as to whether a permanent establishment exists, one of which is the legal right to exercise control over a place of business. ...

3 February 2021 Transfer Pricing Webinar of the Canadian Tax Foundation: Panel IV: Selected Topics in Transfer Pricing-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 MAP referrals for non-s. 247(2) adjustments There is nothing preventing a MAP request relating to a s. 18(1)(a) matter, where that matter potentially gives rise to double-taxation. ...

Income Tax Technical News No. 44 13 April 2011 [archived]-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 use of s.à r.l. ...

[U.K] Revenue and Customs Brief 15 (2015): HMRC response to the Supreme Court decision in George Anson v HMRC (2015) UKSC 44 25 September 2015-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Anson specific to its facts …[T]he [Anson] decision is specific to the facts found in the case. ...