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2018-12-13 to present
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[Repealed, 2014, c. 39, s. 25]
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[Repealed, 2014, c. 39, s. 25]
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2014-12-16 to 2018-12-13
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in[Repealed, respect2014, ofc. each39, ofs. the second affiliate and the third affiliate for each relevant taxation year of that affiliate, either that affiliate is subject to income taxation in that country in that relevant taxation year, or the members or shareholders of that affiliate (which, for the purpose of this sub-subclause, includes a person that has, directly or indirectly, an interest, or for civil law a right, in a share of the capital stock of, or in an equity interest in, the affiliate) at the end of that relevant taxation year are subject to income taxation in that country on, in aggregate, all or substantially all of the income of that affiliate for that relevant taxation year in their taxation years in which that relevant taxation year ends,25]
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[Repealed, 2014, c. 39, s. 25]
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2009-03-12 to 2014-12-16
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in respect of each of the second affiliate and the third affiliate for each relevant taxation year of that affiliate, either that affiliate is subject to income taxation in that country in that relevant taxation year, or the members or shareholders of that affiliate (which, for the purpose of this sub-subclause, includes a person that has, directly or indi-rectly,indirectly, an interest, or for civil law a right, in a share of the capital stock of, or in an equity interest in, the affiliate) at the end of that relevant taxation year are subject to income taxation in that country on, in aggregate, all or substantially all of the income of that affiliate for that relevant taxation year in their taxation years in which that relevant taxation year ends,
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in respect of each of the second affiliate and the third affiliate for each relevant taxation year of that affiliate, either that affiliate is subject to income taxation in that country in that relevant taxation year, or the members or shareholders of that affiliate (which, for the purpose of this sub-subclause, includes a person that has, directly or indirectly, an interest, or for civil law a right, in a share of the capital stock of, or in an equity interest in, the affiliate) at the end of that relevant taxation year are subject to income taxation in that country on, in aggregate, all or substantially all of the income of that affiliate for that relevant taxation year in their taxation years in which that relevant taxation year ends,
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2007-12-14 to 2009-03-12
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the amounts paid or payable are relevant in computing the liability for income taxes in that countryrespect of the members of a group of corporations composedeach of the second affiliate and onethe orthird moreaffiliate otherfor foreigneach affiliatesrelevant taxation year of thethat taxpayeraffiliate, (the shares of which are excluded property)either that areaffiliate resident andis subject to income taxation in that country and in respectthat ofrelevant which the taxpayer has a qualifying interest throughout thetaxation year, or the members or shareholders of that affiliate (which, for the purpose of this sub-subclause, includes a person that has, directly or indi-rectly, an interest, or for civil law a right, in a share of the capital stock of, or in an equity interest in, the affiliate) at the end of that relevant taxation year are subject to income taxation in that country on, in aggregate, all or substantially all of the income of that affiliate for that relevant taxation year in their taxation years in which that relevant taxation year ends,
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in respect of each of the second affiliate and the third affiliate for each relevant taxation year of that affiliate, either that affiliate is subject to income taxation in that country in that relevant taxation year, or the members or shareholders of that affiliate (which, for the purpose of this sub-subclause, includes a person that has, directly or indi-rectly, an interest, or for civil law a right, in a share of the capital stock of, or in an equity interest in, the affiliate) at the end of that relevant taxation year are subject to income taxation in that country on, in aggregate, all or substantially all of the income of that affiliate for that relevant taxation year in their taxation years in which that relevant taxation year ends,
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2004-08-31 to 2007-12-14
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the amounts paid or payable are relevant in computing the liability for income taxes in that country of the members of a group of corporations composed of the second affiliate and one or more other foreign affiliates of the taxpayer (the shares of which are excluded property) that are resident and subject to income taxation in that country and in respect of which the taxpayer has a qualifying interest throughout the year, or