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CRA finds that capital for purposes of determining a Canadian Treaty-reduced dividend withholding rate of 5% references stated capital

Summary of 14 December 2023 External T.I. 2019-0820291E5 under Treaties – Income Tax Conventions – Art. 10. ...

CRA indicates that the 3-month threshold for a drilling rig to be a PE under the Canada-US Treaty is counted based on days of consecutive or non-consecutive use including standby time

Summary of 23 November 2023 Internal T.I. 2020-0850381I7 under Treaties – Income Tax Conventions – Art. 5. ...

CRA suggests that a non-resident’s increasing its voting shareholding in Canco to access the Treaty-reduced dividend withholding rate does not engage the PPT

Summary of 15 May 2024 IFA Roundtable, Q.1 under Treaties – Income Tax Conventions – Art. 10. ...

CRA explains the credit for US estate taxes under Art XXIX-B(6)(a) of the Canada-US treaty

Summary of 4 June 2024 STEP Roundtable, Q.11 under Treaties – Income Tax Conventions – Art. 29B. ...

PepsiCo – Full Federal Court of Australia finds that concentrate purchases by an Australian soft drink bottler could not be recharacterized as trademark royalties for withholding tax purposes

Summaries of PepsiCo, Inc v Commissioner of Taxation [2024] FCAFC 86 under Treaties – Income Tax Conventions – Art. 12. ...

CRA rules that using employees to provide on-line health services to non-resident patients from home offices in Canada does not create a PE in Canada

Summary of 2024 Ruling 2023-0984281R3 under Treaties – Income Tax Conventions – Art. 5. ...

Guide for the Partnership Information Return (T5013 Forms)

Box 119 – Foreign business income that is exempt from Canadian tax due to a tax convention or agreement (multi-jurisdictional) Enter any part of foreign business income that is exempt from Canadian tax due to a tax convention or agreement. ... Box 112 – Foreign net rental income that is exempt from Canadian tax due to a tax convention or agreement (multi-jurisdictional) All partners – Enter any part of foreign rental income that is exempt from Canadian tax due to a tax convention or agreement. ... Box 157 – Foreign capital gains exempt from Canadian tax due to a tax convention or agreement (Multi-jurisdictional) Enter the foreign capital gain that is exempt from Canadian tax due to a tax convention or agreement. ...

Entertainment Software Association v. SOCAN - Supreme Court decision casts doubt on withholding tax exemption for artistic production royalties

Additional issues arise under similarly-worded exemptions in various Income Tax Conventions to which Canada is a party (but which should also give effect to the intent of the other Treaty partner), given that (as noted in the dissenting reasons of Rothstein J.) the copyright law of foreign jurisdictions such as the U.S. may be structured quite differently than the Canadian Copyright Act. ...

Fowler v. HMRC Commissioners - First-Tier Tribunal finds that “treatment is the meaning:” employment income deemed by U.K. domestic legislation to be from carrying on a “trade” was therefore deemed by Art. 3(2) to be “business profits” for Treaty purposes

Brannan J also stated: If a Contracting State changes its domestic law after the conclusion of a double tax treaty in such a way as to reallocate income from one article to another...that could contravene the requirements of good faith imposed by Article 31(1) of the Vienna Convention.... ...

Société générale valeurs mobilières – Tax Court of Canada finds that a Brazilian tax sparing provision did not permit the taxpayer to shelter Canadian-source income

. … In addition, the provision quoted above was similar to the equivalent in the 1977 OECD Model Convention, except that the OECD provision used the word “attributable” rather than “appropriate” (although, both provisions used “correspondant” in their French versions). ...

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