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The arm's length principle is stated in paragraph 1 of Article 9 of the OECD Model Tax Convention: "Where... conditions are made or imposed between... two [non-arm's length] enterprises in their commercial or financial relations which differ from those which would be made between [arm's length] enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly. ... These rules: are generally found in Article IX of the relevant treaty; are often modelled after Article 9 of the OECD Model Tax Convention on Income and on Capital; and provide a framework in which adjustments to profits by one country's tax administration may be offset by a corresponding adjustment by the tax administration of another country. 216. ... The reader may refer to the most recent version of Information Circular 71-17, Requests for Competent Authority Consideration Under the Mutual Agreement Procedures in Income Tax Conventions. ...

The arm's length principle is stated in paragraph 1 of Article 9 of the OECD Model Tax Convention: "Where... conditions are made or imposed between... two [non-arm's length] enterprises in their commercial or financial relations which differ from those which would be made between [arm's length] enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly. ... These rules: are generally found in Article IX of the relevant treaty; are often modelled after Article 9 of the OECD Model Tax Convention on Income and on Capital; and provide a framework in which adjustments to profits by one country's tax administration may be offset by a corresponding adjustment by the tax administration of another country. 216. ... The reader may refer to the most recent version of Information Circular 71-17, Requests for Competent Authority Consideration Under the Mutual Agreement Procedures in Income Tax Conventions. ...

The arm's length principle is stated in paragraph 1 of Article 9 of the OECD Model Tax Convention: "Where... conditions are made or imposed between... two [non-arm's length] enterprises in their commercial or financial relations which differ from those which would be made between [arm's length] enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly. ... These rules: are generally found in Article IX of the relevant treaty; are often modelled after Article 9 of the OECD Model Tax Convention on Income and on Capital; and provide a framework in which adjustments to profits by one country's tax administration may be offset by a corresponding adjustment by the tax administration of another country. 216. ... The reader may refer to the most recent version of Information Circular 71-17, Requests for Competent Authority Consideration Under the Mutual Agreement Procedures in Income Tax Conventions. ...

For information on: GST/HST rebates for non-residents that purchase tour packages and for non-resident non-registered tour operators that purchase short-term and/or camping accommodation and sold it as part of an eligible tour package, see GST/HST Memorandum 27.3, Foreign Convention and Tour Incentive Program – Rebate for Eligible Tour Packages and Accommodation Supplied as Part of Eligible Tour Packages; when a supply is made in or outside Canada, see GST/HST Memorandum 3.3, Place of Supply; and when a passenger transportation service would be zero-rated if the service was supplied separately and not as part of a tour package, see GST/HST Memorandum 28.3, Passenger Transportation Services. ...

For information on: GST/HST rebates for non-residents that purchase tour packages and for non-resident non-registered tour operators that purchase short-term and/or camping accommodation and sold it as part of an eligible tour package, see GST/HST Memorandum 27.3, Foreign Convention and Tour Incentive Program – Rebate for Eligible Tour Packages and Accommodation Supplied as Part of Eligible Tour Packages; when a supply is made in or outside Canada, see GST/HST Memorandum 3.3, Place of Supply; and when a passenger transportation service would be zero-rated if the service was supplied separately and not as part of a tour package, see GST/HST Memorandum 28.3, Passenger Transportation Services. ...

Our partnerships The CCRA works with the following organizations, and in doing so, contributes to the shared federal goals and objectives for SD: EC, CFIA, DFAIT, AAFC, HC, CIC, CCG, DFO administering various regulations and agreements relating to their respective programs (see below for a list of legislation and regulations administered by the CCRA) EC under the Joint Services Initiative related to the Convention on the International Trade in Endangered Species of Wild Fauna and Flora (CITES), specialized training is provided to some customs officers Finance and DFAIT to ensure that proposed legislative changes and international agreements are administratively feasible and economically viable as well as to assess the implications for the fiscal framework RCMP, CIC, DFAIT to locate and reunite missing children with their lawful parents and guardians DFAIT in a standing committee to share information and consult on each other's departmental priorities and initiatives, such as the Customs Blueprint, and the Kyoto Convention Finance, SGO, RCMP, Justice, CSIS, CIC in a working group charged with drafting the revised Proceeds of Crime (money laundering) Act INAC on First Nations' issues related to compliance with treaty agreements, border protection, trade and tax administration Finance, OCED, PATA and other international organizations on electronic commerce issues other levels of government to eliminate federal/provincial duplication of services that result in the reduced overall cost of government services and savings to the public federal departments and agencies to open the door to reliable consumer information through the Canadian Consumer Information Gateway RCMP in the development and implementation of a Memorandum of Understanding for the secondment of CCRA personnel to the Integrated Proceeds of Crime (IPOC) units across Canada Justice on forensic tax fraud prosecutions internationally in support of a number of economic and trade initiatives in international fora, such as the North American Trade Agreement (NAFTA), the Asia Pacific Economic Cooperation (APEC), the G7, the Free Trade Agreement of the Americas, and the World Customs Organization; and in the Organization for Economic Co-operation and Development (OECD) and Pacific Association of Tax Administration (PATA) to share experiences and best practices related to tax administration with numerous world customs agencies to share experiences and best practices related to enforcement with respect to the movement of goods across international boundaries LEGEND CFIA Canadian Food Inspection Agency DFAIT Department of Foreign Affairs and International Trade AAFC Agriculture and Agri-Food Canada HC Health Canada DFO Department of Fisheries and Oceans CIC Citizenship and Immigration Canada CCG Canadian Coast Guard PWGSC Public Works and Government Services Canada RCMP Royal Canadian Mounted Police EC Environment Canada Finance Department of Finance SGC Solicitor General of Canada CSIS Canadian Security and Intelligence Service INAC Indian and Northern Affairs Canada List of legislation administered by the CCRA Acts under the responsibility of the Minister of National Revenue, including certain acts for which the Minister of National Revenue has a role. ... Income Tax Conventions Interpretations Act North American Free Trade Agreement Implementation Act............................................. c. 44 Petroleum and Gas Revenue Tax Act..................... ...

Form GST106 – Information related to foreign conventions and tour packages This tick box is generally not relevant for builders. It may only apply if you paid or credited the amount of a rebate for a foreign convention or a tour package and you are reporting that amount on your GST/HST NETFILE return. ...

Forms and publications listed by topic Atopics Btopics Ctopics Dtopics Etopics Ftopics Gtopics Htopics Itopics Jtopics Ktopics Ltopics Mtopics Ntopics Otopics Ptopics Qtopics Rtopics Stopics Ttopics Utopics Vtopics Wtopics Xtopics Ytopics Ztopics A Annual Report to Parliament Appeals B Business and professional income Business Number (BN) C Canada Child Benefit Capital gains Charities Child and Family Benefits Child care expenses Children's Special Allowances Contract Payment Reporting Corporate Business Plan Corporate income tax D Day care Deceased persons: Preparing their tax returns Disabilities, People with Donations and Gifts E E-commerce Employment expenses Exchange rates Excise duty Excise tax F Farming Fishing Flow-through share (FTS) Program Foreign conventions Foreign reporting Foreign spin-offs G Gifts and income tax GST/HST GST/HST credit GST/HST Domestic Rebate Program H Harmonization of Sales Taxes in Ontario and British Columbia Home Buyers' Plan (HBP) Housing rebate I Instalments International social security agreement forms L Lifelong learning plan (LLP) M Medical expenses Moving Mutual funds N Non-profit organization (NPO) Northern residents deductions P Partnerships Payroll People with disabilities Public service bodies R RRSP/RRIF income returns Registered education savings plans (RESP) Registered retirement savings plans (RRSP) Rental income Retirement S Students and income tax Support payments T Tour packages Trusts V Voluntary disclosures Report a problem or mistake on this page Thank you for your help! ...

Generally, these activities are as follows: promoting one or more art forms; conducting research into one or more art forms; sponsoring arts exhibitions or performances; representing interests of the arts community or a sector of it (but not of individuals) before government or other public bodies; conducting workshops, seminars, training programs, and similar development programs relating to the arts for members of the organization for which the value of the benefits received is included in determining the incomes of those members; educating the public about the arts community or the sector represented by the organization; organizing and sponsoring conventions, conferences, competitions, and special events relating to the arts community or the sector represented by the organization; conducting arts studies and surveys of interest to members of the organization relating to the arts community or the sector represented by the organization; acting as an information centre by maintaining resource libraries and data bases relating to the arts community or the sector represented by the organization; disseminating information relating to the arts community or the sector represented by the organization; and providing scholarships, bursaries, and awards relating to the arts community or the sector represented by the organization. ...

Income tax rulings and technical interpretations The Income Tax Rulings Directorate in the Legislative Policy and Regulatory Affairs Branch is the Canada Revenue Agency’s (CRA’s) authority for the interpretation of the Income Tax Act, the Income Tax Regulations and all related statutes including Income Tax Conventions. ...