Permanent Establishment

Administrative Policy

27 February 2020 CBA Roundtable, Q.21

Based on Bulletin B-090, a server may constitute a fixed place of business if the server is at the non-resident’s disposal and the server’s...

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P-208R "Meaning of Permanent Establishment in Subsection 123(1) of the Excise Tax Act (the Act)" 23 March 2005

Meaning of fixed place of business

…The fact that space at the disposal of a particular person is at the place of business of another person...

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22 October 2004 RITS 38169

A U.S. company would not have a permanent establishment in Canada by virtue only of subcontracting with a Canadian affiliate for the Canadian...

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