Abstract
This article examines some of the main features of Canada's tax laws and policies regarding the taxation of permanent establishments (PEs). The article discusses the definition of PE in Canada's tax treaties and sets out the tax laws and policies on agency PEs and the PE fiction permitting the taxation of non-resident entertainers and athletes. The article also reviews Canada's approach to attributing profits to PEs under the recent OECD reform efforts. The article concludes tentatively that Canada appears to be following a worldwide trend of diluting the "fixed place of business" requirement for a traditional PE in order to address changing global commercial realities.
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