PE developments in response to COVID-19
Canada: Updated guidance on COVID-19 and PEs
On 1 April 2021, the Canadian Revenue Agency (CRA) updated its guidance on international income tax issues raised by the COVID-19 crisis. Among other items, the guidance clarifies the CRA’s position regarding the effect of travel restrictions on permanent establishment (PE) in Canada.
First, the relief period (from 16 March until 30 September 2020) is no longer applicable to cases regarding whether a nonresi…