Canadian Tax Journal, Volume 38, Issues 1-3Canadian Tax Foundation., 1990 - Taxation |
From inside the book
Results 1-3 of 46
Page 259
... ESTABLISHMENT OR FIXED BASE EXCEPTION An obvious question is why did the OECD , in the 1977 model treaty , add paragraph 2 to article 21 dealing with the permanent establishment or fixed base exception ? Specifically , it can be asked ...
... ESTABLISHMENT OR FIXED BASE EXCEPTION An obvious question is why did the OECD , in the 1977 model treaty , add paragraph 2 to article 21 dealing with the permanent establishment or fixed base exception ? Specifically , it can be asked ...
Page 260
... establishment in the other state.94 Because of the permanent establishment exception , if interest or dividends are paid by a resident of state A to a taxpayer also resident in state A , but they are paid in respect of property that is ...
... establishment in the other state.94 Because of the permanent establishment exception , if interest or dividends are paid by a resident of state A to a taxpayer also resident in state A , but they are paid in respect of property that is ...
Page 609
... establishment if it is given the general authority to contract on behalf of its principal . Income from Real Property and Timber Interests Ownership of real property in Canada does not by itself constitute a per- manent establishment ...
... establishment if it is given the general authority to contract on behalf of its principal . Income from Real Property and Timber Interests Ownership of real property in Canada does not by itself constitute a per- manent establishment ...
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