Article 8

Cases

Furness, Withy & Company Limited v. Minister of National Revenue, 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221

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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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Locations of other summaries Wordcount
Tax Topics - Treaties - Articles of Treaties - Article 12 computer tracking-system charges of a Danish company to local agents were profits of its international shipping business rather than for technical services 334

Administrative Policy

23 October 2012 External T.I. 2011-0431301E5 - Meaning of Substantial Operation

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14 February 2012 External T.I. 2011-0428531E5 - Art. VIII, 6 Canada-US Tax Convention

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31 October 1991 T.I. (Tax Window, No. 12, p. 17, ΒΆ1559)

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