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The Queen, 2008 DTC 3631, 2008 TCC 306-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 A U.S. ...

Dudney, 2000 DTC 6169 (FCA)-- summary under Article 14 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 14 The taxpayer (a U.S. resident) provided his services, as independent contractor, to a nonresident corporation which, in turn, was hired by a Canadian company ("PanCan") to assist it in creating a computer system. ...

The Queen, 2014 DTC 1040 [at at 2723], 2013 TCC 404-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 5-year limitation did not apply to secondary Part XIII assessment FCA appeal settled. ...

., 2009 DTC 5721, 2009 FCA 57-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 The taxpayer paid dividends to its shareholder, ("Prévost Holding"), a Netherlands holding company which, in turn, paid dividends in substantially the same amount to its two corporate shareholders, a Swedish and UK corporation. ...

Income Tax Convention (a claim which, in this case, was unsupported by the evidence). ...

Valentine Maritime (Mauritius) Ltd. (2010), 38 DTR 117 (Mumbai ITAT)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 projects not interconnected The taxpayer ("Valentine") was a Mauritius company which carried on several construction projects in India, in connection with which it provided construction services in India for various customers. ...

The Queen, 2006 DTC 2705, 2006 TCC 246-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 The taxpayer provided a fully-crewed vessel under a charter party to a Canadian resident company for the purpose of transporting pipe and other materials from Nova Scotia to two ships of the Canadian company laying pipe off the coast of Nova Scotia within the Sable Island offshore area. ...

Morgan Stanley (2007), 9 ITLR 1124 (India SC)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 "seconded" employees remained employees of non-resident so that services provided The taxpayer ("MSCo") sent its employees to its subsidiary in India ("MSAS") to oversee MSAS's staff in monitoring the outsourcing activities at MSAS and also sent employees on secondment (or "deputation") to MSAS. ...

Derrin Brothers Properties Ltd & Ors, R (on the application of) v A Judge of the First Tier Tribunal (Tax Chamber) & Ors, [2016] BTC 10, [2016] EWCA Civ 15-- summary under Article 27 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27 documentary demands made by HMRC pursuant to Art. 27 on UK companies being investigated by Australia were valid The Australian Tax Office, which suspected that a UK accounting firm was providing nominee directors and shareholders to UK-incorporated companies to make them look like they were factually resident outside Australia, made a request to the UK Revenue (HMRC) pursuant to Art. 27 of the UK-Australia Treaty (somewhat similar to Art. 24 of the Canada-U.K. ...

(C)-7416/2012 (Delhi High Court)-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 charges for use of the installer’s own equipment were not royalties for equipment use The taxpayer was a Singapore company which installed a marine crude oil receiving facility over a 41-day period for Indian Oil Corporation Ltd (“IOCL‟) at a contract price of U.S.$18.6 million. ...