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This principle is articulated by the Organisation for Economic Co-operation and Development (OECD) in Article IX of the OECD Model Convention on Income and Capital and is the international consensus approach to transfer pricing determination for member countries of the OECD. ...

GST/HST guides RC188  Keeping Records GST/HST memoranda 27-2   Conventions GST/HST notices Notice244 Harmonized Sales Tax for Ontario – Questions and Answers on Housing Rebates and Transitional Rules for Housing and Other Real Property Situated in Ontario Notice245 Supreme Court of Canada Decision – United Parcel Service Canada Ltd. v. ...

. ¶1.110 (formerly ¶16 of IT-478R2) has been modified to explain what is meant by a 115.1 agreement (an agreement to defer Canadian tax), to update the reference (Income Tax Folio S5-F2-C1, Foreign Tax Credit), and to add a reference to Information Circular 71-17R5, Guidance on Competent Authority Assistance under Canada’s Tax Conventions. ¶1.112 (formerly the second half of ¶17 of IT-478R2) has been amended to clarify the treatment of CCA recapture arising on the disposition of real or immovable property for which an election under section 216 has been previously made. ...

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. ...

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..................... ...

GST/HST Forms GST190A GST/HST New Housing Rebate – Appendix A GST370 Employee and Partner GST/HST Rebate Application (revised) RC1C Business Number (BN)- Import/Export Account Information (revised) RC59 Business Consent Form (revised) GST/HST Info Sheets GI-015 GST/HST Rate Reduction and Purchasers of New Housing- July 2007 (revised) GI-037 Children's Camps Operated by Public Sector Bodies GI-038 The 2008 GST/HST Rate Reduction GI-039 Applying the 2008 GST/HST Rate Reduction to Allowances and Reimbursements GI-040 Applying the 2008 GST/HST Rate Reduction to Prepaid Funeral and Cemetery Arrangements GI-041 GI-041- The 2008 GST/HST Rate Reduction and Streamlined Methods of Accounting for Small Businesses GI-042 Applying the 2008 GST/HST Rate Reduction to Price Adjustments, Adjustments for GST/HST Overcharged, and Returned Goods GI-043 The 2008 GST/HST Rate Reduction and Purchases of New Housing GST/HST Notices Notice143 Application of GST/FNGST to Yukon First Nations and their Members (revised) Notice221 Questions and Answers on the Cancellation of the Visitor Rebate Program and the Implementation of the New Foreign Convention and Tour Incentive Program (revised) Notice222 Implementation of the Kwanlin Dun First Nations Goods and Services Tax (FNGST) Notice223 Implementation of the Nunatsiavut First Nations Goods and Services Tax (FNGST) Notice224 Draft Policy Statement: The GST/HST Real Property Implications of Constructing, or Purchasing, and Operating a Residential Care Facility Notice225 For Discussion Purposes Only, Draft Revised GST/HST Memorandum 3.3.1, Drop Shipments Notice226 Proposed GST/HST Rate Reduction in 2008 Notice227 The Order Amending the Labrador Innu Settlements Remission Order, 2003 Comes into Force GST/HST Policy Statements P-194R2 Application of Penalties and Interest when a Return and/or Rebate Application, and/or Another Return, is Received after the Due Date P-196R Whether Administrative Overhead Costs Fall under Subsection 186(1) of the Excise Tax Act P-218R Tax Status of Damage Payments, Whether or not Within Section 182 of the Excise Tax Act GST/HST Technical Information Bulletins B-096 GST/HST Rate Reduction and Real Property B-097 Determining Whether a Financial Institution is a Qualifying Institution for Purposes of Section 141.02 B-098 Application of Section 141.02 to Financial Institutions That Are Qualifying Institutions B-099 Application of Section 141.02 to Financial Institutions That Are Not Qualifying Institutions B-100 Standardized Accounting Excise Forms E638 Application for Exemption From Premium Taxes Imposed Under the Excise Tax Act- Part 1 E638A Statement of availability or declination from authorized insurers- Tax on insurance premiums (Part 1 of the Excise Tax Act) Excise Duty Memoranda EDM3-8-1 Special Containers of Spirits (revised) EDM4-8-1 Special Containers of Wine (revised) EDM10-3-1 Refunds Excise Duty Notices EDN16 Tobacco Products Inventory Tax January 1, 2008. ...

Income Tax Conventions Interpretations Act North American Free Trade Agreement Implementation Act Petroleum and Gas Revenue Tax Act P-12 Privileges and Immunities (North Atlantic Treaty Organization) Act Public Utilities Income Tax Transfer Act P-37 Special Import Measures Act S-15 Surcharge on Imports Order Act, etc., 1963 c. 18 Tax Rebate Discounting Act T-3 (SI/95-102) Trade Marks Act T-13 (ss. 53 to 53.3) World Trade Organization Agreement Implementation Act Appendix E- Other Information (continued) 13 References 1997-98 and 1998-99 Reports on Plans and Priorities 1998 Income Tax Statistics Compliance: From Vision to Strategy Customs and Trade Administration Blueprint: A Discussion Paper Index to Revenue Canada Services Revenue Canada: Benefit Programs Revenue Canada Web site (http://www.rc.gc.ca) Date modified: 2002-01-04 ...

Subsection 115.1(1) May, under a provision contained in a tax convention or agreement, enter into an agreement with another person with respect to the taxation of the other person, and all determinations made in accordance with the agreement shall be deemed to be in accordance with the Act Headquarters Positions Deputy Assistant Commissioner, Compliance Programs Branch Director General, International and Large Business Directorate Director, Competent Authority Services History: Delegation in respect of subsection 115.1(1) was amended on November 6, 2014 and May 20, 2008. ...

See Information Circular IC76-12, Applicable rate of part XIII tax on amounts paid or credited to persons in countries with which Canada has a tax convention. ...