17 November 2023 External T.I. 2023-0965891E5 - Section 115.2 -- summary under Paragraph 2(3)(b)

A limited partnership (“Foreign LP”) has exclusively non-resident partners and its Canadian corporate general partner has delegated the management of its activity of making loans to an affiliated Canadian-resident manager. Although para. (a) of the definition of “designated investment service” in s. 115.2(1) relevantly excluded only investment management and advice, CRA indicated that mere administrative services performed by the Manager would not by themselves cause the limited partners to be considered to be carrying on business in Canada (and similarly regarding any administrative services of the GP.)