Services Permanent Establishments and the Canada–United States Income Tax Treaty

Journal
Wilkie, J.S.
Canada
International Transfer Pricing Journal 2012 (Volume 19), No. 3
FormatPDF
EUR
40
| USD
45
(VAT excl.)

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.