Friday, May 6, 2011

Canada-Turkey Tax Treaty

The Canada-Turkey Tax Treaty came into force on May 4.

A couple of items of interest in the treaty articles I have already covered in this blog.

One is the residence rule for other than individuals is quite specific.  The treaty states that if the two countries cannot agree on where a person is resident, that person will not be able to claim any treaty benefits.  

The other is that, similar to the Canada-US Treaty, a permanent establishment will include services performed in the other state for a period or periods of more than 183 days in any twelve month period.  

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