Residence of Companies Under Tax Treaties and EU Law (Canada)
RESIDENCE OF COMPANIES UNDER TAX TREATIES AND EC LAW, Guglielmo Maisto, ed., pp. 407-440, Amsterdam: IBFD, 2009
23 Pages Posted: 15 Jul 2009 Last revised: 7 Dec 2009
Date Written: July 15, 2009
This chapter reviews the development and present Canadian law on the residence of corporations for tax purposes. It highlights a few of the elements of Canada's corporate law regime by way of context; outlines why residence matters to corporations for Canadian tax purposes, traces the history of the Canadian tests for corporate residence, explains how the Canadian Income Tax Act addresses continuances, and reviews the approach to the determination of corporate residence reflected in Canada's tax treaties.
Keywords: corporate tax, tax policy, taxation
JEL Classification: K00
Suggested Citation: Suggested Citation