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A Canadian entity entered into contract with a CA vendor to provide services to upgrade various sites in various countries. The vendor will use local service in different countries to carry out work.

What are tax implications for billing to various countires? Any tax rebates to be aware of? Also any withholding requirements outside Canada remittances?

I will really appreciate insights of international tax gurus!

Thanks!
 

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Ashley,

Could you please clarify a few things?

From your original posting, as I understand it, we have a Canadian company that is the taxpayer. That Canadian company has subsidiaries (or permanent establishments) in foreign countries. The Canadian company contracts with an unrelated party vendor to provide certain services to the Canadian company and its subsidiaries. The unrelated party vendor contracts with other unrelated parties to provide services to the Canadian company's foreign subsidiaries. Is this right?

Your question, as I understand it, is about what tax issues involved, or whether there are rebates or deductions to be had.

It will be difficult to provide much commentary unless you can provide more details.

As it stands, I can see potential for transfer pricing issues. This is an area in which I have some knowledge, but if you need specific tax advice or an opinion, you should probably consult your accountant. You can PM me if you don't want to post more details on the board.
 
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