Canada - Services Permanent Establishments and the Canada–United States Income Tax Treaty
- J. Scott Wilkie
- International Transfer Pricing Journal, 2012 (Volume 19), No 3
- 9 May 2012
This article explains the “services permanent establishment” provision in the Canada–United States Income Tax Treaty in the context of the OECD’s views on this extension of the typical PE notion, and in light of several interpretative comments offered by the Canada Revenue Agency.