Article 12

Cases

MCA Television Ltd. v. The Queen, 94 DTC 6375 (FCTD)

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The Queen v. St. John Shipbuilding & Dry Dock Co. Ltd., 80 DTC 6272, [1980] CTC 352 (FCA)

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Words and Phrases
royalties rentals

Vauban Productions v. The Queen, 75 DTC 5371, [1975] CTC 511 (FCTD), aff'd 79 DTC 5371, [1979] CTC 262 (FCA)

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MNR v. Paris Canada Films Ltd., 62 DTC 1338, [1962] CTC 538 (Ex Ct)

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Western Electric Co. Inc. v. MNR, 69 DTC 5204 (Ex Ct), briefly aff'd 71 DTC 5068 (SCC)

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See Also

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

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Words and Phrases
technical service
Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 8 computer tracking-system charges of a Danish company to agents in India were profits of its international shipping business 186

DCIT v. Bombardier Transportation India Pvt. Ltd, ITA No.555/Ahd/2016 (ITAT Ahmedabad)

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Tech Mahindra Limited v Commissioner of Taxation, [2016] FCAFC 130

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Words and Phrases
effectively connected

Technip Singapore Pte Ltd. v. Director of Income Tax, W.P.(C)--7416/2012, 2 June 2016 (Delhi High Court)

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 5 major installation project lasting 41 days was not a PE 104

Velcro Canada Inc. v. The Queen, 2012 DTC 1100 [at 2966], 2012 TCC 57

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Tax Topics - General Concepts - Agency alleged agent had discretion and no power to bind 133

Canada v. Dawn’s Place Ltd., [2006] GSTC 137, 2006 FCA 349

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Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part V - Part V-10 use of copyright in downloading images was only incidental 111

Angoss International Ltd. v. The Queen, 99 DTC 567 (TCC)

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Administrative Policy

1 June 2018 External T.I. 2017-0723051E5 - Meaning of "Relieved from Tax"

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 29 Canadian royalties received exempt of U.K. tax by non-dom U.K. resident not eligible for Treaty-reduced rate 265

16 August 2017 Internal T.I. 2017-0701291I7 - Exclusive Distributorship Rights

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Words and Phrases
royalty
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) Farmparts likely excluded application to product distributorship right/product name on product not a valuable use of trademark 477
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) lump sum non-contingent payment for distributorship right was not a royalty 99
Tax Topics - Income Tax Act - Section 56.4 - Subsection 56.4(1) - Restrictive Covenant a lump sum paid to a non-resident for granting an exclusive right to distribute its product in Canada was for a restrictive covenant 250
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(i) a lump sum paid to a non-resident for granting an exclusive right to distribute its product in Canada was subject to s. 212(1)(i) withholding 199

15 June 2015 External T.I. 2014-0525501E5 - Royalty payments & the US or UK Treaties

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21 April 2015 External T.I. 2013-0494251E5 - 128.1(4) and Part XIII tax on future payments

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(4) - Paragraph 128.1(4)(b) right to client list utilization payments 111
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(v) client list utilization payments to U.S. resident 133

23 January 2015 External T.I. 2013-0509771E5 - Oil & gas payments made to U.S. resident

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(iii.1) negative CCDE pool for non-resident individual 170
Tax Topics - Income Tax Act - Section 66.4 - Subsection 66.4(5) - F FMV addition and subtraction where drilling rights are granted for royalty 137
Tax Topics - Income Tax Regulations - Regulation 805 application to resource royalties 235
Tax Topics - Treaties - Income Tax Conventions - Article 6 negative CCDE gain from grant of oil and gas royalty not exempt under US Treaty 166

18 November 2013 Internal T.I. 2011-0399581I7 F - Application of section 212(1)(d) ITA

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) seriatim benchmark lump sums, although not royalties, came within s. 212(1)(d) 146
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(viii) cost-sharing agreement with catch-up payment provisions qualified 83

21 September 2012 External T.I. 2012-0457951E5 - Fee for Information

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27 August 2012 External T.I. 2011-0416181E5 - US internet publisher - CDN resident advertiser

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2 August 2012 External T.I. 2011-0422781E5 - Part XIII tax-fee to use on-line trading program

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2012 Ruling 2011-0416821R3 - Article XII of Canada-US Tax Convention

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2011 Ruling 2011-0416891R3 - Fees for Digital Content & Management Services

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(4) - Paragraph 212(4)(a) management of on-line store 228

1 February 2012 External T.I. 2012-043157 -

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Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 6 51

22 February 2011 External T.I. 2011-0374421E5 -

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19 April 2011 External T.I. 2011-0392761E5 - Motion picture films, ITA 212(5)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(5) film reproduction in encrypted form 91

TPM-06 "Bundled Transactions" 16 May 16 2005

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) 141

Income Tax Technical News, No. 25, 30 October 2002, "E-Commerce"

2002 Tax Executives Institute Roundtable Q. 19, 2002-0173855 -

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Income Tax Technical News, No. 23, 18 June 2002

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15 October 1997 T.I. 970018

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19 February 1997 T.I. 961630

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27 June 1996 T.I. 960522

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1996 Ontario Tax Conference Round Table, Q. 3 (No. 9630040)

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1996 Ontario Tax Conference Round Table, Q. 1 (No. 9630030, see also 9621950a)

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6 September 1995 T.I. 951889

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22 March 1995 External T.I. 5-941918 -

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6 March 1995 Memorandum 942876 (C.T.O. "Video Reproduction Rights")

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(5) 16

20 December 1994 T.I. 942143

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3 August 1994 T.I. 910885 (C.T.O. "Withholding Tax Computer Software Royalties")

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29 July 1994 T.I. 941869

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93 C.R. - Q. 29

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93 C.M.TC - Q. 11

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5 January 1993 T.I. 922053 (November 1993 Access Letter, p. 509, ¶C180-153; Tax Window, No. 28, p. 8, ¶2404)

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14 October 1992 Rulings Tax Seminar Central Region 9230057

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4 March 1992 Memorandum (Tax Window, No. 17, p. 11, ¶1781)

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10 January 1990 T.I. (June 1990 Access Letter, ¶1281)

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