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Last Updated 31/07/2024
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Ask a questionCanada’s tax treaties generally state that a non-resident corporation’s business profits are not subject to Canadian tax unless the corporation conducts business in Canada through a PE in Canada, and the profits are attributed to that PE. Canada’s tax treaties may also limit branch tax to cases where the non-resident corporation conducts business in Canada through a PE and/or restrict the branch tax rate. A PE is generally defined as:
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In some cases, a Canadian PE may arise when services are provided in Canada, and certain requirements (e.g., duration of the services) are met.
The Canadian domestic definition of PE (federal and provincial/territorial) generally mirrors the above.
The interpretation of what constitutes a PE is expected to be re-evaluated due to the 2015 final report by the OECD and G20 on Action 7, focused on preventing the artificial avoidance of PE status.
MEMBERSHIP LEVELS —
The Curator is a fully-fledged member of the Tax Natives team. As such, they are capable of making introductions to other Tax Natives and are also able to take leads from their fellow Natives.
The Creator is a fully-fledged member of the Tax Natives team. As such, they are capable of making introductions to other Tax Natives and are also able to take leads from their fellow Natives.
The Adviser is a fully-fledged member of the Tax Natives team. As such, they are capable of making introductions to other Tax Natives and are also able to take leads from their fellow Natives.
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Become a curator
TAX NATIVES: CURATOR — CuratorThe Curator is a fully-fledged member of the Tax Natives team. As such, they are capable of making introductions to other Tax Natives and are also able to take leads from their fellow Natives. |
Become a creator
TAX NATIVES: CREATOR — CreatorThe Creator is a fully-fledged member of the Tax Natives team. As such, they are capable of making introductions to other Tax Natives and are also able to take leads from their fellow Natives. However, the Creator has additional responsibilities. They commit to their other Natives that they will produce at least one piece of quality content each quarter – whether an article, video or other valuable content. There are multiple Creator memberships available for each jurisdiction. Where a Curator fulfils their commitments then they receive a 100% discount against their monthly membership fee. |
Become an adviser
TAX NATIVES: ADVISOR — AdviserThe Adviser is a fully-fledged member of the Tax Natives team. As such, they are capable of making introductions to other Tax Natives and are also able to take leads from their fellow Natives. The Adviser Native is a care-free soul and has made no other commitments to his fellow Tax Natives to generate content or curate a jurisdictional page. That's cool. However, the Adviser will be eligible to pay the full monthly membership fee. |
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| Initial admin fee | £250 Free | £250 Free | £250 Free |
| Minimum membership term | 12 months | 12 months | 12 months |
Article contentCreator and Curators must create at least one piece of original, quality-approved content each quarter. |
No | YesCreator and Curators must create at least one piece of original, quality-approved content each quarter. |
No |
| Managing and updating your jurisdiction page |
Yes |
No |
No |
NATIVE
TAX NATIVES: CURATOR —
The Curator is a fully-fledged member of the Tax Natives team. As such, they are capable of making introductions to other Tax Natives and are also able to take leads from their fellow Natives.
However, the Curator has additional responsibilities. They are tasked with the responsibility of managing and updating one of the jurisdiction pages.
There is only one Curator membership available for each jurisdiction.
Where a Curator fulfils their commitments then they receive a 100% discount against their monthly membership fee.
| Initial admin fee | £250 Free |
| Minimum membership term | 12 months |
Article contentCreator and Curators must create at least one piece of original, quality-approved content each quarter. |
No |
| Managing and updating your jurisdiction page | Yes |
TAX NATIVES: CREATOR —
The Creator is a fully-fledged member of the Tax Natives team. As such, they are capable of making introductions to other Tax Natives and are also able to take leads from their fellow Natives.
However, the Creator has additional responsibilities. They commit to their other Natives that they will produce at least one piece of quality content each quarter – whether an article, video or other valuable content.
There are multiple Creator memberships available for each jurisdiction. Where a Curator fulfils their commitments then they receive a 100% discount against their monthly membership fee.
| Initial admin fee | £250 Free |
| Minimum membership term | 12 months |
Content creationCreator and Curators must create at least one piece of original, quality-approved content each quarter. |
YesCreator and Curators must create at least one piece of original, quality-approved content each quarter. |
| Managing and updating your jurisdiction page | No |
TAX NATIVES: ADVISOR —
The Adviser is a fully-fledged member of the Tax Natives team.
As such, they are capable of making introductions to other Tax Natives and are also able to take leads from their fellow Natives.
The Adviser Native is a care-free soul and has made no other commitments to his fellow Tax Natives to generate content or curate a jurisdictional page.
That's cool.
However, the Adviser will be eligible to pay the full monthly membership fee.
| Initial admin fee | £250 Free |
| Minimum membership term | 12 months |
Content creationCreator and Curators must create at least one piece of original, quality-approved content each quarter. |
No |
| Managing and updating your jurisdiction page | No |
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