installation

Before concluding that “it would be reasonable to conclude that a software development business carried on outside Canada by a specified employer can constitute an installation or engineering activity for the purposes of section 122.3,” the Directorate stated that “a particular employer that carries on a business abroad relating to the coordination and implementation of software, as well as the introduction of financial management systems, could probably successfully argue th

Art. V, subpara. 2(g) of the Canada-Brazil Treaty included an "assembly project" in the definition of permanent establishment, rather than using the term "installation project." After noting that this provision likely was based on Art. 5 of the 1963 OECD Model, which used "assembly project," before this was changed in 1977 without comment to "installation project," referring to dictionary definitions of "assemble" and "install," and noting that the French Treaty versions generally used "montage" for both terms, CRA stated: