2021 Ruling 2019-0800191R3 - Carrying on business in Canada. -- summary under Subparagraph 115(1)(a)(ii)

CRA ruled that the provision of various services by Canco to its immediate foreign parent and to other non-resident members of the group would not by themselves cause those members to carry on business in Canada. These services consisted of various “computer services” including hosting the group website on a Canadian servicer and handling email and time and billing systems and central network management services, as well as “other support services” including accounting, financial, anti-money laundering, compliance, administrative support, information resources management and marketing services. Canco would not have the authority to execute or deliver any contract, agreement or instrument in the name of, or on behalf of, or to act as agent of, its parent or any other non-resident member of the group.