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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. ...

5 April 2015 CRA Press Release (respecting Panama Papers)-- summary under Article 27 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 27 CRA will communicate with Treaty partners to obtain any missing Panama Papers Recent media coverage raises questions about leaked documents from a Panama law firm relating to the offshore financial affairs of numerous individuals worldwide....The Agency is actively pursuing the cooperation of its tax treaty partners and the International Consortium of Investigative Journalists to obtain all of the leaked records that pertain to Canadian residents. ...

TPM-2, on secondary adjustments and repatriation, which is in its final stages of approval, and CRA is working on TPM-3, dealing with downward adjustments, in conjunction with updates to IC 71-17, Guidance on Competent Authority under Canada’s Tax Conventions. ...

Income Tax Technical News, No. 41, 23 December 2009 Under "Definition of 'Tax Shelter'- Subsection 237.1(1)-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A sale of shares of USco carrying on parallel business Assume that USco carries on an active business in the United States (other than an investment business). ...

Transfer Pricing Memorandum TPM-06, “Bundled Transactions” 16 May 2005-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 distinction between know-how and services provision After noting the exemption in Art. 12 of the Canada-U.S. ...