DOES TIME ALONE CREATE A PERMANENT ESTABLISHMENT? THE COURTS AND REVENUE CANADA GO THEIR SEPARATE WAYS

Journal
Boidman, N.
Bulletin for International Taxation 2000 (Volume 54), No. 7
PriceUSD 45

This article examines the Federal Court of Appeal's recent decision in Dudney v. Queen regarding the role played by the amount of time spent providing services in a country in determining whether there is a permanent establishment or fixed base for treaty purposes. The article also discusses Revenue Canada's administrative position related thereto and the relationship between the two.