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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: Canada: Source

For the purposes of the credit Article, profits, income and capital gains derived by a resident of one of the countries which may be taxed in the other country in accordance with the provisions of the agreement are deemed to have their source in that other country (Article 21(3) and see INTM161120(c)).