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6 February 2001 External T.I. 2000-0044095 F - Honoraires - retenue d'impôt non-résident -- summary under Article 7

6 February 2001 External T.I. 2000-0044095 F- Honoraires- retenue d'impôt non-résident-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 management fees exempted from withholding by business profits article in Canada-US treaty Regarding whether a Canadian resident corporation should withhold tax on fees it pays for services rendered in the United States by individuals resident in the United States, CCRA indicated that, as the Canada-US treaty did not contain a specific article on management or administration fees and those fees were covered by the business profits provisions, a Canadian resident was not required to withhold pursuant to s. 215(1) with respect to the reasonable portion of management fees paid to a U.S. resident who did not have a permanent establishment in Canada. ...

Teletech Canada, Inc. v. Canada (National Revenue), 2013 DTC 5110 [at at 6090], 2013 FC 572 -- summary under Article 9

Canada (National Revenue), 2013 DTC 5110 [at at 6090], 2013 FC 572-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 After the taxpayer's U.S. parent (TeleTech US) determined that it had undercharged the taxpayer for administrative services provided in 2000-2002, TeleTech US filed amended returns with the IRS to increase its taxable income for those years, and the taxpayer requested CRA (on May 5, 2004) to make a corresponding downward adjustments for those years- which was withdrawn in March 2006 in order to clear the way for a request made of CRA (on May 11, 2006) under Art. ...

Resource Capital Fund III LP v. Commissioner of Taxation, [2013] FCA 363 (Fed. Ct. of Austr.), rev'd supra. -- summary under Article 13

.-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 mine deriving value from information The appellant ("RCF") was a Caymans limited partnership with mostly US-resident partners, which was assessed under the "taxable Australian real property" rules on its gain from the sale of an Australian company ("SBM") with two underground gold mines in Western Australia. ...

Canada v. MIL (Investments) S.A., 2007 DTC 5437, 2007 FCA 236 -- summary under Subsection 245(4)

This result positioned the taxpayer to clearly fit within an exemption from Canadian capital gains tax under Article XIII of the Canada-Luxembourg Income Tax Convention (the "Treaty") on a subsequent disposition of that block of shares once the taxpayer became resident in Luxembourg. ...

Re Nortel Networks Corp., 2014 ONSC 6973 -- summary under Article 9

., 2014 ONSC 6973-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 provision, under multinational agreement for residual profit split method, for unilateral bearing of restructuring costs, represented appropriate ex ante risk allocation In January 2009, Nortel Networks Corporation ("NNC"), which was the publicly-traded Canadian parent filed for protection under the CCAA, various U.S. subsidiaries filed for protection under chapter 11 of the U.S. ...

CIT v. Herbalife International India Pvt. Ltd (2016), ITA 7/2007 (Delhi High Court) -- summary under Article 25

Ltd (2016), ITA 7/2007 (Delhi High Court)-- summary under Article 25 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 25 Indian domestic provision denying the deduction of technical services fees paid to a non-resident where there was a failure to withhold back-up withholding violated the non-discrimination provision in the U.S. ...

Adobe Systems Inc. v. ADIT, W.P.(C) 2384/2013 (Delhi High Court) -- summary under Article 5

(C) 2384/2013 (Delhi High Court)-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 not carrying on business "through" sub's premises if no right to use them A wholly owned Indian subsidiary of the taxpayer (“Adobe India”) provided software related research and development (R&D) services on a cost plus 15% basis to the taxpayer, which was a U.S. ...

Tech Mahindra Limited v Commissioner of Taxation, [2016] FCAFC 130 -- summary under Article 12

Tech Mahindra Limited v Commissioner of Taxation, [2016] FCAFC 130-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 exception in the Australia-India Treaty for “effectively connected” royalties was not intended to exempt royalties not attributable to the source country PE from source country withholding The Indian-resident taxpayer performed services for its Australian customers from its offices in India and through an Australian permanent establishment. ...

DCIT v. Bombardier Transportation India Pvt. Ltd, ITA No.555/Ahd/2016 (ITAT Ahmedabad) -- summary under Article 12

Ltd, ITA No.555/Ahd/2016 (ITAT Ahmedabad)-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 not a technical services royalty if Indian services recipient did not acquire know-how The taxpayer was a wholly-owned Indian subsidiary within the Bombardier group, that was engaged in the business of manufacturing and supply of rail transportation systems. ...

Director of Income Tax v. A.P. Moller Maersk, Civil Appeal No. 2960 of 2017 (Supreme Court Of India, Civil Appellate Jurisdiction) -- summary under Article 12

Moller Maersk, Civil Appeal No. 2960 of 2017 (Supreme Court Of India, Civil Appellate Jurisdiction)-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 computer tracking-system charges of a Danish company to local agents were profits of its international shipping business rather than for technical services The Danish-resident taxpayer had set up and maintained a global telecommunication facility connected to computers in Denmark to assist all of its appointed agents in various countries in booking and tracking of cargo and servicing customers in those countries. ...

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