We found a match
Your institution may have access to this item. Find your institution then sign in to continue.
- Title
Canada.
- Authors
Wilkie, J. Scott
- Abstract
The article focuses on the impact of the ratification of the Fifth Protocol to the Canada-United States Income Tax Convention on the operation of multinational enterprises in Canada. It says that the ratification increases the concerns of developed countries on mobile income. It asserts that the two situations provided by the convention nonresidents service provider in Canada should be scrutinized by multinational enterprises. It states that the measurement of branch profits using the principles of transfer pricing requires a more determined review on the intensity and scope of international business. It also notes the reciprocal limitation and derivative benefits provision as well as the relaxation of withholding tax on the interest paid by nonresidents provider of service.
- Subjects
CANADA; UNITED States; RATIFICATION of treaties; TAXATION of international business enterprises; INTERNATIONAL economic relations; CANADA-United States relations; NONRESIDENTS; TRANSFER pricing taxation; WITHHOLDING tax
- Publication
International Tax Journal, 2009, Vol 35, Issue 3, p19
- ISSN
0097-7314
- Publication type
Article