The taxpayer, a U.K. company, supplied a ship and a crew (obtained under subcontract from a related non-resident company) to a Canadian company for use in transporting pipe joints and other materials from Nova Scotia to an installation used closer to Sable Island.
The fact that the crew received various instructions from the Canadian company was not inconsistent with the Tax Court's finding that the taxpayer was operating the ship and, thus, was "carrying on activities" for purposes of being deemed under Article 27A of the Canada-U.K. Convention to be carrying on business in Canada through a permanent establishment.