Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.
Principal Issues: Whether payments under production sharing agreements are an income or profits tax.
Position: Under review
Reasons:
TEI Conference
December 9, 1997
Question XX
FOREIGN TAX CREDITS - PAYMENTS FOREIGN GOVERNMENT IN
RESPECT OF PRODUCTION SHARING AGREEMENTS
In meetings with the Department of Finance, the Tax Executive Institute has raised the question of the proper foreign tax credit treatment of amounts paid to foreign governments in respect of production sharing contracts for the extraction of natural resources. The Department of Finance has indicated that the issue is under review and that a recommendation for changes to mitigate the problem would be forthcoming.
What is Revenue Canada's current position on the creditability of these payments.
Department's Position
While the Department's position has not changed, the issue is under review.
Author: Olli Laurikainen File: 972980 Date: November 12, 1997