Residence of Companies Under Tax Treaties and EU Law (Canada)

Document Type

Book Chapter

Publication Date



Canadian Tax Law, Corporate Tax, Tax Policy, Taxation, Residence, Canadian Income Tax Act


This chapter reviews the development and present Canadian law on the residence of corporations for tax purposes. It highlights a few of the elements of Canada's corporate law regime by way of context; outlines why residence matters to corporations for Canadian tax purposes, traces the history of the Canadian tests for corporate residence, explains how the Canadian Income Tax Act addresses continuances, and reviews the approach to the determination of corporate residence reflected in Canada's tax treaties.