Article 5

where a UK company remotely operated crypto-mining equipment located on a Canadian host company’s premises, the equipment constituted a Canadian PE

remote customer-support services from the US did not cause a Canadian services PE

having an employee, with general authority to contract, telework from his cottage in another province does not necessarily create an employer PE there

argument, that days cannot be counted twice under the 183-day test for a services PE under the Canada-US Treaty, left open

somewhat isolated (albeit in large amounts) loan activity in US did not represent a business under UK concepts and therefore did not entail a US PE under the UK-US Treaty

French staff who lined up the contracts (albeit “automatically” signed elsewhere) gave rise to dependent-agent PEs

a Mumbai liaison office for a domestic construction project was not a PE in India

quaere whether individual could derive business revenues through his enterprise through an LLC