Article 12

Canada will not reduce its withholding rate to 0% to make room for Quebec taxes imposed on the same property income

concentrate purchases by an Australian soft drink bottler could not be recharacterized as trademark royalties for withholding tax purposes

Irishco’s purchasing a UK interest claim from Caymansco at a tax arbitrage price did not have Treaty-reduction as a main purpose

part of the purchase price for concentrate purchased by an independent Australian bottler from an Australian PepsiCo company was characterized as a trademark royalty paid to PepsiCo

Canada’s withdrawal of its observation on Art. 12 on March 28, 2002 was prospective, and did not affect its right to impose withholding tax on payments for use of a secret process prior to that date

reference to IP royalties does not extend to someone who has no interest in the IP

consideration for software paid by Indian resellers was not royalties for Canadian (and other) Treaty purposes

television and broadcasting included digital streaming

rate reduction inapplicable where received by remittance-based UK resident free of UK tax

lump sum paid for distributorship rights was not a royalty