Income Tax Regulations

413 (1) For the purposes of this Part, where a corporation is not resident in Canada, “salaries and wages paid in the year” by the corporation does not include salaries and wages paid to employees of a permanent establishment outside Canada and “taxable income” shall be deemed to refer to taxable income earned in Canada as determined under section 115 of the Act.

(2) For the purposes of paragraph 402(3)(a), where a corporation is not resident in Canada, “total gross revenue for the year” of the corporation does not include gross revenue reasonably attributable to a permanent establishment outside Canada.