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HMRC internal manual

Double Taxation Relief Manual

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

Under Canadian domestic law, certain non-resident companies carrying on a business in Canada are liable to a supplemental tax on their profits in addition to the normal Income Tax. Article 22(4)(d) exempts the first £250,000 or $C500,000, whichever is the greater, of the profits of the Canadian branch of a United Kingdom company from this supplemental tax.

Where the tax is charged on profits in excess of this amount, it is admissible for tax credit relief.